Sutter Health has agreed to pay $15,117,516 to resolve conduct concerning violations of the Physician Self-Referral Law, commonly known as the Stark Law, as well as double-billing for certain services. The Stark Law prohibits a hospital from billing Medicare for certain services referred by physicians with whom the hospital has a financial relationship, unless that relationship satisfies one of the law’s statutory or regulatory exceptions. The law is intended to ensure that medical decision-making is not influenced by improper financial incentives and is instead based on the best interests of the patient. The conduct at issue was self-disclosed by Sutter to the United States, and includes submission of claims to Medicare that resulted from referrals by physicians to whom certain Sutter hospitals: (1) paid compensation under personal services arrangements that exceeded the fair market value of the services provided; (2) leased office space at below-market rates; and (3) paid reimbursements of physician-recruitment expenses that exceeded the actual recruitment expenses at issue. Additionally, several Sutter ambulatory surgical centers double-billed the Medicare program by submitting claims that included radiological services for which Medicare separately paid another entity that had performed those services.
