Stark law enforcement has never been more active. Here are 10 numbers that capture where the law stands, what it costs and where it is heading:
$6.8 billion. The Department of Justice’s 2025 year-end report shows a record $6.8 billion recovered under the False Claims Act, the highest annual total in the statute’s history, with whistleblowers filing 1,297 qui tam lawsuits. Stark law violations are a significant driver of that enforcement activity.
$2.92 billion. In fiscal year 2024, False Claims Act settlements and judgments totaled $2.92 billion, up from $2.79 billion in 2023, driven in part by seven major Stark law indictments and a record 979 qui tam whistleblower lawsuits.
$480 million. Indianapolis-based Community Health Network settled for $345 million in December 2023, then paid an additional $135 million in January 2025 to resolve the remaining portion of the same whistleblower case, a total of $480 million for alleged physician compensation structured around referral volume rather than fair market value. This is the single largest Stark law enforcement action in DOJ history.
314. CMS resolved 314 Stark law self-disclosure settlements in 2024, totaling more than $24.7 million, nearly twice the previous annual record. An additional 232 disclosures were withdrawn, closed without settlement, or settled by CMS’ law enforcement partners.
552%. CMS resolved $12.56 million in Stark law-related voluntary self-referral disclosure settlements in 2023, a 552% increase since 2021.
$15,000. The fine physicians face for each service provided in violation of Stark law, plus additional civil penalties of up to $100,000 per violation. Whistleblowers can receive up to 30% of the case payout after a Stark law case is accepted and a financial penalty is imposed.
$100 million. The potential damages and penalties facing Chattanooga, Tenn.-based Erlanger Health System in the Stark law False Claims Act case currently in active litigation. A federal judge denied the system’s motions to dismiss in early 2026. Erlanger has maintained it paid physicians based on outside consultants’ fair market value determinations.
$535. The updated non-monetary compensation cap under Stark law as of January 2026, increased from $519 in 2025. The limit governs the value of non-cash items and services a physician can receive from an entity to which they refer patients without triggering a Stark law violation.
10. The number of multimillion-dollar Stark law settlements reported by Becker’s in the two years preceding 2025 alone. This pace of enforcement reflects both increased DOJ willingness to litigate and a more sophisticated whistleblower bar pursuing cases the government might not have prioritized on its own.
1989. The year Congress enacted Stark law, initially targeting physician referrals for clinical laboratory services only. The law officially took effect January 1, 1992, and has since expanded to cover radiology, physical therapy and a range of other Designated Health Services.