The U.S. Department of Justice recently announced a $60 million settlement with the Lester E. Cox Medical Centers (Cox), a non-profit healthcare system based in Missouri, to settle claims that Cox violated the False Claims Act, the anti-kickback statute and the Stark Law by improperly structuring business relationships with physicians and incorrectly billing Medicare. The settlement alleges that between 1996 and 2005, Cox engaged in prohibited financial relationships with physicians by entering into medical directorship agreements that were not in writing, paying physicians more than fair market value, and paying physicians based on the volume of referrals. According to the settlement agreement, Cox entered into a physician services agreement with certain physicians that included in the physician salary calculation the revenue earned from the pharmaceuticals, DME and supplies, clinical laboratory services, radiology services, and neurodiagnostic services provided to Medicare patients treated by those physicians. Billing Medicare for items or services ordered by physicians with whom one has such financial relationships opens the door for liability under the False Claims Act and can lead, as it did here, to weighty penalties. In addition, the settlement agreement resolves claims Cox included non-reimbursable costs on its Medicare cost reports and improperly billed for services provided to dialysis patients. As part of the settlement agreement, Cox has entered into a five-year Corporate Integrity Agreement with the U.S. Department of Health and Human Services Office of Inspector General.