Contents
This ledger lists every source cited in the investigation. Public sources link to the primary record wherever one is available. Private historical records (H series) are described but not linked or published; private message identifiers, mailbox metadata and communications with counsel are never listed. Official documents linked here may identify litigants by name.
ENational enforcement
DOJ, HHS-OIG and court records for national matters and statistics.
- E01
- E02
- E03
- E04
- E05
- E06
- E07
- E08
- E09
- E10
- E11
- E12
- E13
- E14
- E15
- E16
- E17
- E18DOJ C.D. Cal., Los Angeles healthcare fraud actions, 15 defendantsOct. 22, 2026Figures quoted from the release; charges are allegations.Open source
- E19DOJ Office of Public Affairs, national version of the Los Angeles announcementOct. 22, 2026Open source
- E20Indictment, United States v. [two defendants], No. 2:26-cr-00668-JFW (C.D. Cal.)Returned Oct. 20, 2026; ¶21(i), PDF p. 7The linked document names the defendants.Open source
- E21DOJ victim-notification page for the arterial-procedure caseUpdated Oct. 22, 2026The page title names the defendants.Open source
- E22DOJ Civil Division, Fraud Statistics: Overview and HHS tables, Oct. 1, 1986 to Sept. 30, 2025Overview pp. 1–3; HHS pp. 5–7; notesAll 25 annual rows used here were checked against this publication.Open source
- E23DOJ, False Claims Act settlements and judgments exceed $6.8B in fiscal year 2025Jan. 16, 2026Open source
- E24
- E25DOJ, Civil Division and HHS announce Healthcare Self-Disclosure Pilot ProgramOct. 22, 2026Open source
- E26
- E2742 C.F.R. §411.357(w), Stark exception for EHR items and services (eCFR)Current as displayed Oct. 2026Same authority as L09.Open source
- E2842 C.F.R. §1001.952(y), AKS safe harbor for EHR items and services (eCFR)Current as displayed Oct. 2026Same authority as L10.Open source
- E29
- E30HHS-OIG, General Compliance Program GuidanceNov. 2023Voluntary guidance, not a source of liability.Open source
- E31
- E32
FFresno public record
The settlement, court orders, the PACER docket and HHS-OIG records for the Fresno case.
- F01DOJ E.D. Cal., Fresno-based Community Health System agree to pay $31.5 millionMay 14, 2025Credits FBI and USPS-OIG assistance.Open source
- F02Executed settlement agreement: United States, CHS, PNA and relatorEffective May 7, 2025; 25 pp.Recitals B–G; ¶¶1–5, 7, 21; Exhibit A.Open source
- F03HHS-OIG, corporate integrity agreement listing for Fresno Community Hospital and Medical Center d.b.a. Community Health SystemEffective May 7, 2025; est. completion May 2030Lists $31,200,000.Open source
- F04
- F05Order of dismissal as to certain parties and claims, Dkt. 60Signed June 24, 2025; filed June 25Open source
- F06
- F07
- F08Docket index entry for Dkt. 96 (superseded)SupersededIndexed Sept. 15, 2026Superseded by F12; retained for the record of earlier editions.Open source
- F09Third-party docket index (superseded)SupersededIndexed 2026Superseded by F12; retained for the record of earlier editions.Open source
- F10
- F11
- F12PACER civil docket report, No. 1:19-cv-01699-JLT-HBK (E.D. Cal.)Generated Oct. 25, 2026, 3:30:36 p.m. Pacific; entries through Dkt. 101 (Oct. 19, 2026)Controlling procedural source for this edition. PACER requires an account; KPSGILL.com retains the report.Open source
- F13ProPublica Nonprofit Explorer, Santé Health Foundation (EIN 20-0517238)SecondaryTax year 2018 summary; viewed Oct. 25, 2026Extracts IRS e-file data; lists 2018 contributions of $26,405,002 and more than one 2018 filing. Not a certified IRS record.Open source
LLegal authorities
Statutes, regulations, federal guidance and judicial opinions.
- L01
- L0231 U.S.C. §3730, civil actions and qui tam procedure (Office of the Law Revision Counsel)CurrentOpen source
- L0342 U.S.C. §1320a-7b, Anti-Kickback StatuteCurrentStatutory text reproduced by Cornell LII.Open source
- L04United States v. Regeneron Pharmaceuticals, No. 23-2086 (1st Cir.)Feb. 18, 2025Describes the circuit split on AKS causation.Open source
- L05
- L06
- L07
- L0842 U.S.C. §1395nn, physician self-referral (Stark) lawCurrentStatutory text reproduced by Cornell LII.Open source
- L09
- L10
- L11HHS-OIG, frequently asked questions on fraud and abuse authoritiesUpdated 2026Explains that Stark compliance does not establish AKS compliance, and that failing a safe harbor is not itself a violation.Open source
- L12
- L13
- L14
- L15United States ex rel. Silingo v. WellPoint, Inc., 904 F.3d 667 (9th Cir.)Amended Sept. 11, 2018Open source
- L16United States ex rel. Zafirov v. Florida Medical Associates, LLC, No. 24-13581 (11th Cir.)Sept. 1, 2026 (published)Qui tam provisions do not violate the Appointments Clause; other challenges remanded.Open source
- L17IRS, public inspection and copies of exempt-organization documents (IRM 11.3.9; 26 C.F.R. §301.6104(d)-1)CurrentFormerly listed as H10.Open source
- L18United States v. Kats, 871 F.2d 105 (9th Cir. 1989)Citation1989Adopts the “one purpose” test for the Anti-Kickback Statute in the Ninth Circuit. Reporter citation.
- L19OIG final rule revising AKS safe harbors, including EHR donations, 85 Fed. Reg. 77684Dec. 2, 2020; effective Jan. 19, 2021Companion CMS Stark rule at 85 Fed. Reg. 77492.Open source
ACalifornia and additional authorities
State law, state guidance and other authorities used to qualify historical claims.
- A01California Health and Safety Code §1206(l), as reproduced in AB 1130 (enrolled Sept. 3, 2015)2015Enrolled bill reproducing the section's text; not described as a chaptered act.Open source
- A02California DHCS, hospital worker-retention-payment eligibility FAQUpdated Dec. 9, 2022Recognizes hospital-related §1206(l) clinics in another context.Open source
- A03IRS Revenue Procedure 97-13 and successor Revenue Procedure 2017-131997; 2017Rev. Proc. 97-13 made Rev. Proc. 93-19 obsolete.Open source
- A04Epic Medical Management, LLC v. Paquette, 244 Cal.App.4th 504Filed Dec. 29, 2015; published Jan. 28, 2016Arbitration posture limits its reach.Open source
- A05California Attorney General, amicus brief in Art Center Holdings v. WCE CA ART, B338625Mar. 30, 2026Advocacy filing, not an appellate holding; later disposition not verified.Open source
- A0642 C.F.R. §1001.952(y) as published in the 2015 Code of Federal Regulations2015 annual editionThe version in force for 2015 transactions.Open source
- A07California SB 351 (2025): private-equity and hedge-fund involvement in physician and dental practicesSigned Oct. 6, 2025; effective Jan. 1, 2026The list of reserved decisions was confirmed against a law-firm summary; verify against the chaptered text before quoting it.Open source
HPrivate historical records
Correspondence and documents held in a private archive. Described, not published.
- H01Seven-page open letter, “Depiction of Business of Medicine in the Shades of Grey”Private, not linkedOct. 8, 2015Original attachment preserved unchanged. Quoted at pp. 2–5. States its author's views, not findings. Personal names omitted.
- H02Contemporaneous circulation of the letterPrivate, not linkedOct. 8–9 and 27, 2015Selected email records establish sending and requests for distribution; they do not show that any recipient read it.
- H03Exemption-application correspondencePrivate, not linkedOct. 16–26, 2015Includes the Oct. 22 inspection offer and copying restriction and Oct. 26 scheduling. A separately referenced written response has not been recovered.
- H04EHR access correspondence with Epic and PNAPrivate, not linkedDec. 2011 to Jan. 2012; Nov. 2015 forwardOriginal inquiry, referral, vendor representation, physician's questions and vendor replies. No original 2010 inquiry has been verified.
- H05PNA meeting and health-information-exchange correspondencePrivate, not linkedMar. 15–16, 2016The executive's brief reply precedes the physician's later follow-up. A reported 2016 FBI call is not independently corroborated.
- H06FBI meeting scheduling and follow-upPrivate, not linkedJune 10–18, 2019Supports a meeting on or about June 14, 2019. The messages do not identify the organizations or transactions later at issue.
- H07Copy of Santé Health Foundation's 2018 Form 990, 30 pp.Private, not linkedTax year 2018Privately supplied copy. Not yet matched to the IRS-filed return; its figures are withheld from this edition.
- H08Earlier private historical evidence review, 47 pp.Private, not linked2026Secondary working analysis with 53 source and lead anchors; not an exhaustive mailbox export.
Reviewed and approved for publication by Kanwar Partap Singh Gill, MD.