top of page

Healthcare Compliance

Physician compensation arrangements and STARK considerations

Timothy M. Wogan, JD, CHC

June 29, 2026

A recent False Claims Act (FCA) ruling out of Tennessee offers a pointed reminder for hospitals and health systems: physician contracts that appear compliant on paper can still create serious enforcement risk if the economics tell a different story. In denying motions to dismiss FCA claims involving Erlanger Health System (Erlanger), the federal court allowed allegations regarding physician compensation to proceed, reinforcing that these arrangements remain fertile ground for qui tam relators and the Department of Justice (DOJ). For organizations contracting with physicians, the message is clear: independent fair market value (FMV) review, rigorous documentation, regular auditing, and meaningful board oversight are essential defenses, not mere optional safeguards.

Continue the Conversation

This article has a dedicated discussion inside the Exchange.  Share your perspective, ask questions, and learn from other healthcare professionals

Join the Conversation

Members sign in to participate

Not a member? Join The Exchange

Related Insights

View All

Title
Date

Catergory

Heading 6
Title

Realted Insight Ca

Heading 6
Title

Realted Insight Ca

Related Discussions

View All

Title
Date

Catergory

Heading 6
Title

Realted Insight Ca

Heading 6
Title

Realted Insight Ca

Upcoming Events

ChatGPT Image Jul 6, 2026, 05_33_32 PM.png
OCTOBER BRIEFING
AI in Healthcare: 
Legal & Regulatory Implications

October 16, 2026

12:00 PM EST

Virtual Event

bottom of page