Tenet Healthcare Corp. didn’t admit any wrongdoing when it reached a civil settlement with the government earlier this year over alleged Medicare fraud. But the company voluntarily made a significant number of personnel changes, an apparent acknowledgment that not everything was right at the Dallas-based hospital chain. In addition to bringing on several new executives and directors, about 80 of the 97 vice presidents who were at Tenet prior to January 2003 are now gone. The shake-up was one of several major reforms that the company has implemented over the last few years.

The sweeping personnel overhaul at Tenet was “uncommon,” says Peter Henning, a former lawyer in the criminal division of the U.S. Department of Justice. Now a law professor at Wayne State University, Henning adds, “When you get down a couple of levels into management, that’s a substantial change” — and one that rarely happens.