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
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
