There is a Stark case mentioned here in which the defendant paid a $713,623 fine to resolve allegations that it had subleased space in its hospital to physicians at below market rates.  In once instance, OIG alleged that a physician did not pay rent for FIVE YEARS.  Oops.  In addition to the penalty, the defendant agreed to enter into a cerification of compliance agreement.  It is also of interest that the defendant self disclosed the conduct, perhaps a reason why they were not excluded from Medicare.