Stark Integrity: Recent Episodes
Bob Wade
Does your healthcare organization have an effective compliance program? Captain Integrity is here to save the day. Learn how to roll out necessary, lighthearted, and fun education to your employees and physicians so they abide by Stark Law. Hosted by Bob Wade aka Captain Integrity, award-winning Healthcare Regulatory and Stark Law Attorney
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Why are private equity, physician groups, and the Stark Law like insects heading to a bug zapper? In this episode, Captain Integrity Bob Wade explains why. Hear why ownership changes do not eliminate Stark Law risk, why compensation redesign deserves careful attention, why documentation is your best defense, the mother of all definitions, and the research behind insects being attracted to light bulbs. Learn more at WadeHealthLaw.com
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You can now experience Stark Integrity in 2 ways: the podcast AND the blogs. In this episode, Captain Integrity Bob Wade introduces the Stark Integrity Podcast Blogs, where you can enjoy each episode as 1 conversation, with 2 experiences. Hear what to expect with the new Stark Integrity website, how your favorite Stark Integrity topics & episodes are now searchable, the goal of Stark Integrity from the very beginning, how to use the new site as a research tool, and how your feedback helped shape the new site. Check out the new site at WadeHealthLaw.com
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In a recent episode of Stark Integrity, Captain Integrity Bob Wade made an incorrect statement regarding Erlanger Health and a Stark Law case. In this brief update, he sets the record straight. Learn more at CaptainIntegrity.com
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Lean in wherever you have quick wins. In this episode, Captain Integrity Bob Wade talks using AI in physician contracting & payment as they relate to the Stark Law with Scott Lowry, Founder of StarkWatch. Hear how to quickly assess where your organization’s at with its Stark Law compliance program, how to aim for advancement instead of program perfection, why you should use inexpensive AI solutions to perform reviews & monitoring, some of the use cases for StarkWatch, and a bit of nostalgia for old school, offline resources. Learn more at CaptainIntegrity.com
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Training goes a long way when it comes to informed consent. In Part 3 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear why you need to document the decision-making capacity, how to make sure AI use is properly disclosed, why policies & procedures play a huge role, how AI is changing the healthcare world, and how surrogates work. Learn more at CaptainIntegrity.com
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The more checks and balances an organization has along the way, the greater the protection for both the patients & the providers. In Part 2 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear how decision-making capacity & inadequate informed consent lead to legal liability, considerations when it comes to anesthesia, personal anesthesia stories from Bob & Rachel, the best practices organizations can take to uphold patient autonomy, and notable high-profile cases involving sexual assault. Learn more at CaptainIntegrity.com
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The patent’s right to autonomy is one of the core principles of the patient-provider relationship. In Part 1 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear the recent cases where informed consent & decision-making capacity were relevant, the difference between decision-making capacity & informed consent, why having the piece of paper signed doesn’t necessarily mean informed consent, how providers & patients can protect themselves, and what you should think through as a patient before moving forward with anything. Learn more at CaptainIntegrity.com
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You should be able to duct tape your mouth & hands and give your documentation to the payer, and they should still be able to generally understand what happened. In Part 2 of this 2-part episode, Captain Integrity Bob Wade continues his discussion on holistic audits and synchronizing professional & facility reviews under the Stark Law with Kelly Loya & Bruce Truitt of Pinnacle Enterprise. Hear how to consider all entities of the claim, when to consider unified sampling, how to help payers, how the 60-day overpayment rule works, and how to handle the discussion that the file is closed. Learn more at CaptainIntegrity.com
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You can’t audit the whole ocean. In Part 1 of this 2-part episode, Captain Integrity Bob Wade discusses holistic audits and synchronizing professional & facility reviews under the Stark Law with Kelly Loya & Bruce Truitt of Pinnacle Enterprise. Hear what holistic audits are, the different types of reviews, the benefits of sampling a patient encounter, how to maintain an unbiased sample, and the parable of the blind men and an elephant. Learn more at CaptainIntegrity.com
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There is indeed a return on investment (ROI) for an effective compliance program. In this episode, Captain Integrity Bob Wade quantifies that ROI as it relates to the Stark Law. Hear why the ROI can be 2x-5x what the organization is investing, how the cost for non-compliance is 2x-3x higher, why you shouldn’t look at the compliance program as just a cost center, examples of compliance program ROI calculations, and your ROI if you would have invested in Apple & Disney in the early days. Learn more at CaptainIntegrity.com
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When analyzing a physician financial arrangement under the Stark Law, you also need to analyze it under the Anti-Kickback Statute (AKS). In this episode, Captain Integrity Bob Wade explains why most of the exceptions under the Stark Law cross-reference the Anti-Kickback Statute. Hear all about the Stark Law & Anti-Kickback Statute dance, the 3 ways to meet the definition of not violating the Anti-Kickback Statute, how to ensure your team understands the intent basis under the Anti-Kickback Statute, specific definitions to keep in mind, and what the Stark Law & Anti-Kickback Statute have to do with The Wizard of Oz. Learn more at CaptainIntegrity.com
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The definition of an “Entity” under the Stark Law includes Managed Care Organizations (MCOs) and the Anti-Markup Rule. In this episode, Captain Integrity Bob Wade details this “Entity” definition under the Stark Law. Hear who the “Entity” usually is, why they expanded the definition, the very narrow exception they came up with, examples of an “Entity” in action, and Bob recite some Miranda Lambert lyrics. Learn more at CaptainIntegrity.com
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When a physician doesn’t perform 100% of the services covered by a surgical period, you may have to consider splitting out the global wRVUs. In this episode, Captain Integrity Bob Wade talks global wRVUs and personally performed services as they relate to the Stark Law. Hear the 3 separate categories when a service is covered by a global payment, what happens when a physician didn’t technically perform all the services for a global payment, when it’s possible the physician could be compensated above fair market value (FMV), a little bit of wRVU math, and some interesting facts about Around the World in 80 Days. Learn more at CaptainIntegrity.com
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False Claims Act settlements (FCA): they just keep getting bigger. In this episode, Captain Integrity Bob Wade details the notable False Claims Act settlements for 2025. Hear how qui tam cases continue to represent the largest source of settlements through the Department of Justice (DOJ) and False Claims Act, what it means if the government declines to intervene, why medical necessity continues to be a very large focus, a shocking settlement involving a physician, and fun examples of things that just keep getting bigger. Learn more at CaptainIntegrity.com
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There are some uses of the isolated transaction exception that are prohibited under the Stark Law. In this episode, Captain Integrity Bob Wade dives into that isolated transaction exception. Hear why the isolated transaction exception has been expanded, the times when it can be used for service arrangements, how it can be used for settlement of a bona fide dispute, the nuances of the isolated transaction exception, and the history of the famous song, “All by Myself.” Learn more at CaptainIntegrity.com
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Beware of the enemy within. In Part 2 of this 2-part episode, Captain Integrity Bob Wade talks cybersecurity and the False Claims Act (FCA) with returning guest and Nelson Mullins Partner Bart Daniel. Hear how to guide outside contractors through certification, why you need to monitor & protect any vulnerabilities as they arise, how to disclose any shortcomings when discovered & be cooperative, where cybersecurity fits in the Top 3 enforcement priorities for the False Claims Act, and how to go about vulnerability testing. Learn more at CaptainIntegrity.com
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Cybersecurity and the False Claims Act (FCA) have more in common than you think. In Part 1 of this 2-part episode, Captain Integrity Bob Wade talks cybersecurity and the False Claims Act with returning guest and Nelson Mullins Partner Bart Daniel. Hear the history of the False Claims Act, fascinating stats on whistleblowers, the impact of Trump’s executive order on cybersecurity from June 2025, the certifications needed in cybersecurity, and some delicious candy bar history. Learn more at CaptainIntegrity.com
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There are some exceptions to the broad definition of an ownership interest under the Stark Law. In this episode, Captain Integrity Bob Wade explains what are not ownership interests under the Stark Law. Hear why the definition does have exceptions, how most of the exceptions are deemed to be compensation arrangements, how to treat an unsecured loan, the 7 types of exceptions, and the original version of “The devil is in the details.” Learn more at CaptainIntegrity.com
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Understanding the definition of an ownership interest is crucial under the Stark Law. In this episode, Captain Integrity Bob Wade shares why loans are ownership interests under the Stark Law. Hear why you need to know & understand all definitions under the Stark Law, why ownership interests also include loans & bonds under the Stark Law, why you should always self-report, key takeaways from a recent Stark Law settlement, and the history of the “When in Rome” proverb. Learn more at CaptainIntegrity.com
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Artificial Intelligence (AI) needs a little pushback. In Part 2 of this 2-part episode, Captain Integrity Bob Wade continues his talk on the intersection of AI, Fair Market Value (FMV), the Stark Law, and the Anti-Kickback Statute (AKS) with HealthValue Group Managing Partner Chris David. Hear why we need to be human to make AI helpful, how to protect your nonproprietary data AI can’t replicate, why survey data & valuation models are a commodity now, why AI won’t replace you as healthcare consultants, and an exercise involving a letter generated by Copilot. Learn more at CaptainIntegrity.com
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Artificial Intelligence (AI) can save a lot of time, but you need to use it wisely. In Part 1 of this 2-part episode, Captain Integrity Bob Wade talks the intersection of AI, Fair Market Value (FMV), the Stark Law, and the Anti-Kickback Statute (AKS) with HealthValue Group Managing Partner Chris David. Hear how AI is already impacting the healthcare consulting industry, notable cases involving AI, the top use cases for AI tools, how AI-generated documents are viewed under the Stark Law, and whether the government is accepting AI. Learn more at CaptainIntegrity.com
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Federally Qualified Health Centers (FQHCs) serve a medically underserved population. In this episode, Captain Integrity Bob Wade talks FQHCs, the Anti-Kickback Statute (AKS), and the Stark Law. Hear whether the Stark Law applies to FQHCs, the wide range of financial arrangements that can happen, why it’s important to document those financial arrangements, the most important rules & provisions to follow, and the history of the “pulling together” phrase. Learn more at CaptainIntegrity.com
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Preparing expert witnesses for their testimony is an arduous process. In this episode, Captain Integrity Bob Wade dives into expert witness selection, preparing, and utilization with White Collar Crime Attorney Sean McKenna. Hear how to select the right expert witness, how to ensure the privileges are maintained, how to perform role playing during cross-examinations, the types of cases ripe for expert witnesses, and how to refute an expert witness. Learn more at CaptainIntegrity.com
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Actively use Artificial Intelligence (AI). In Part 3 of this 3-part episode, Captain Integrity Bob Wade talks AI in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear why the implementation of AI technology will separate the winners & losers, how to explore AI applications as a Compliance Officer, how to think of AI governance like the development of a robust compliance program, the ties between AI governance & autonomous cars, and what AI use in healthcare will look like in 3-5 years. Learn more at CaptainIntegrity.com
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Being unbiased & fair is critical in the healthcare space. In Part 2 of this 3-part episode, Captain Integrity Bob Wade talks Artificial Intelligence (AI) in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear examples of how AI can be used in compliance, the key questions to put on the table, where there’s greater risk, whether it will eventually be considered malpractice if you’re not using AI in healthcare, and how worried compliance teams should be about bias with AI tools. Learn more at CaptainIntegrity.com
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Healthcare laws weren’t designed with artificial intelligence (AI) in mind. In Part 1 of this 3-part episode, Captain Integrity Bob Wade talks AI in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear where AI is already delivering real value in healthcare law & compliance today, the governance & risk management building blocks related to AI, the pros & cons of AI as it relates to existing healthcare laws, how AI compares to other tech revolutions over the years, and why AI might even be its own species. Learn more at CaptainIntegrity.com
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Evaluating the effectiveness of a compliance program is a very important step. In this episode, Captain Integrity Bob Wade describes what a compliance effectiveness review is all about. Hear what the 8th element of an effective compliance program is, who should do the reviewing, why it’s all about culture, what Bob looks at in a review, and infamous examples where organizations failed to test effectiveness. Learn more at CaptainIntegrity.com
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Build in time for back & forth. In this episode, Captain Integrity Bob Wade breaks down how to deliver bad news with Mimi Bliss, Leadership Communications Consultant with Bliss Communications. Hear the power of the pause, how to use starter or transition phrases, why you should keep it short & simple, what to do if an executive keeps interrupting you, and the key phrases to avoid. Learn more at CaptainIntegrity.com
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This week’s Stark Integrity is a compilation of all the Christmas holiday specials from 2021-2025. Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” “Jolly OIG Agent,” “The 12 Days of Compliance,” and “Captain Integrity.” Share the poems with your team and learn more at CaptainIntegrity.com
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It’s time for the 2025 Stark Integrity podcast Christmas Special! In this special holiday episode, Captain Integrity Bob Wade reflects on 2025 and sings his latest custom Stark Law holiday carol, a “Santa Baby” parody. Hear Bob’s professional highlights from the year, the latest with his grandkids & Disney World, his accident involving a ladder, the history of “Santa Baby,” and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com
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Audit results could lead to False Claims Act liability (FCA). In this episode, Captain Integrity Bob Wade talks through audits and potential FCA liability under the Stark Law. Hear why you should do probe audits, when you need to take corrective action, how to avoid the draconian fines & penalties under the FCA, famous cases involving the FCA, and not-so-funny examples of things that go from bad to very ugly. Learn more at CaptainIntegrity.com
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Some spouses may not know their financial arrangements may implicate the Stark Law. In this episode, Captain Integrity Bob Wade explains the marital considerations under the Stark Law. Hear when the Stark Law is implicated, why you need to train people who are approving payments to understand who owns the companies and their ties to physicians, how to exercise due diligence as it relates to the Stark law, just how broad the Stark Law can be, and entertaining marriage movies over the years. Learn more at CaptainIntegrity.com
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You need to know what AI tools your organization is working with. In this episode, Captain Integrity Bob Wade dives into AI use (Artificial Intelligence) and guardrails in healthcare with Natalie Ramello, VP, Chief Compliance & Audit Officer, UT Southwestern Medical Center. Hear why integrity is the launchpad for innovation, how to protect the data, why AI requires accountability, why AI can hallucinate, and an AI-inspired rendition of Captain Integrity’s 3 Punch Points. Learn more at CaptainIntegrity.com
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Could “personally performed” services be compared to a self-driving vehicle? In this episode, Captain Integrity Bob Wade talks the parallels under the Stark Law. Hear why “personally performed” is frequently quoted in the Stark Law and Stark Law exceptions, what deems a service to be a referral, why a referral would not meet the Stark Law exceptions, whether the situation gets tricky, and Bob’s experience with a Zoox autonomous vehicle. Learn more at CaptainIntegrity.com
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TPE (Targeted Probe and Educate) audits look benign, but could be scary. In this episode, Captain Integrity Bob Wade explores TPE audits with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to know if you’re an outlier, the importance of responding timely, why the best defense is a strong offense, how a TPE audit works, and a bunch of things that look benign - but could kill you. Learn more at CaptainIntegrity.com
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Interviews are key for risk assessment. In this episode, Captain Integrity Bob Wade dives into the value of compliance advisory support with Sheila Limmroth, Executive Consultant and Compliance Officer at Pinnacle Healthcare. Hear why advisory does not equal incompetence, how to grow from within, how to build a stronger compliance program, why no person or compliance program is perfect, and how nobody knows everything. Learn more at CaptainIntegrity.com
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Boo! In this special Halloween episode, Captain Integrity Bob Wade shares his original poem “Captain Integrity and the Curse of Stark Hallow” and a trip down Halloween costume history. Hear the most popular Halloween costumes from 1950-2005, the top Halloween costume on your birth year, Bob’s all-time favorite Halloween costume, the common theme with Halloween costumes over the years, and Bob’s special Halloween poem “Captain Integrity and the Curse of Stark Hallow.” Email Bob to get a printed copy of the poem and learn more at CaptainIntegrity.com
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For every dollar of open payments money that goes into a hospital staff, there’s $7 of increase in spend on average to those firms. In this episode, Captain Integrity Bob Wade talks transparency & action as they relate to The 2025 Open Payments Report with Aaron Narva, CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts, how to know your healthcare data better than anyone else, how to use your healthcare data as a strategic advantage, why there’s a systemic problem, and the ice cream truck example. Learn more at CaptainIntegrity.com
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If you’re going to give a gift to one physician, give it to all your physicians. In this episode, Captain Integrity Bob Wade rebroadcasts Part 3 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear an insightful Q&A session on non-monetary compensation and medical staff incidental benefits, how to handle gift certificates under the Stark Law, what to do when your organization is scared of being audited, the compliant way to give holiday gifts to physicians, and how to stay compliant when there’s a big dinner out for the staff. Use code: CaptainIntegrity for a one-time $20 discount on a new AAPL membership and learn more at CaptainIntegrity.com
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Doctors believe the medical staff funds are owned by them. In this episode, Captain Integrity Bob Wade rebroadcasts Part 2 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the benefits you can provide, how to handle lunches for doctors, the difference between employed & independent physicians as it relates to the Stark Law, value vs. cost considerations, and how to think about Joe on the street. Use code: CaptainIntegrity for a one-time $20 discount on a new AAPL membership and learn more at CaptainIntegrity.com
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There’s a lot to consider when it comes to the Stark Law. In this episode, Captain Integrity Bob Wade rebroadcasts Part 1 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the basics of the Stark Law, notable exceptions, whether you can accept gifts in the healthcare industry, what to do if you’ve made a mistake in Stark Law compliance, and some Captain Integrity strips. Use code: CaptainIntegrity for a one-time $20 discount on a new AAPL membership and learn more at CaptainIntegrity.com
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The False Claims Act (FCA) has 3 knowledge qualifiers. In this episode, Captain Integrity Bob Wade unpacks the difference between actual knowledge, deliberate ignorance, and reckless disregard as it relates to the Stark Law. Hear why the 3 knowledge qualifiers exist, how risk impacts the False Claims Act, why you have to look at the history with respect to reviews, examples of the knowledge qualifiers with the healthcare compliance context, and that famous line from A Few Good Men. Learn more at CaptainIntegrity.com
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Performing billing and documentation audits & reviews are important for an effective compliance program. In this episode, Captain Integrity Bob Wade explains what a probe review is and when you need to keep digging for a statistically valid review. Hear how to design your probe review using the RAT-STATS program, when you can treat your probe review as an educational review, when you need to do a statistically valid review, the history of RAT-STATS, and the origin of the “keep on digging” idiom. Learn more at CaptainIntegrity.com
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The misuse of Modifier 25 can result in overcompensation if the physician is being compensated through a wRVU productivity model. In this episode, Captain Integrity Bob Wade lays out the connection between Modifier 25 and wRVUs as they relate to the Stark Law. Hear what questions to ask when it comes to Modifier 25, how to document separateness & significance, the connection between auditing for Modifier 25 and the Stark Law, the 4 criteria to use with Modifier 25, and the origin of Going the Extra Mile. Learn more at CaptainIntegrity.com
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Don’t shoot the messenger. In this episode, Captain Integrity Bob Wade explores the nature of delivering bad news as a Compliance Officer & beyond. Hear how to deliver bad news, why you should soften the soil, how to use the sandwich approach when delivering bad news, the dangers of sugarcoating, and the history of the phrase Don’t Shoot the Messenger. Learn more at CaptainIntegrity.com
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Auditor: you are not a Compliance Officer. In this episode, Captain Integrity Bob Wade dives into the complementary roles of Compliance Officer and Auditor. Hear the difference between the two roles, what each position is responsible for, why the roles are separate & distinct, the history of the Charles Horton Cooley looking-glass self quote, and some notable Hamilton lyrics. Learn more at CaptainIntegrity.com
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Audit yourself. In this episode, Captain Integrity Bob Wade tackles the 2025 healthcare enforcement priorities with Brook Andrews, Partner at Nelson Mullins. Hear why healthcare enforcement is not going away, how the government’s healthcare enforcement tools will continue to get better, how to build a culture of transparency, who healthcare enforcement is targeting, and the parable of the blind men and the elephant. Learn more at CaptainIntegrity.com
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If medical staff funds are in a hospital account, the Stark Law applies. In this episode, Captain Integrity Bob Wade details medical staff funds as they relate to the Stark Law. Hear when the Stark Law applies, why the medical staff funds are restricted, what to consider if the medical staff funds are not in a hospital account, the risks when it comes to medical staff funds, and why this is a controversial topic. Learn more at CaptainIntegrity.com
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If you’re paying your doctor for an hour of service, you better make sure your doctor is working an hour of service. In this episode, Captain Integrity Bob Wade breaks down what happens when financial arrangements exceed Fair Market Value (FMV). Hear why it’s important to keep tabs on your doctors, why monitoring is such a key component of compliance, what to do if financial arrangements exceed FMV, a case example of unethical billing practices, and the Top 10 PSA that inspired this episode. Learn more at CaptainIntegrity.com
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Healthcare providers should be concerned. In this episode, Captain Integrity Bob Wade explores the new DOJ and HHS False Claims Act Working Group targeting healthcare fraud with Knicole Emanuel, Partner at Nelson Mullins. Hear why you should review your compliance program, reassess your risk exposure, consider voluntary disclosure, the areas the working group is targeting, and why this is a paradigm shift for the healthcare industry. Learn more at CaptainIntegrity.com
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The larger the country, the longer it takes to get trials approved. In this episode, Captain Integrity Bob Wade explores how compliance works for national & international clinical trials with Julio Martinez-Clark, CEO of bioaccess. Hear how clinical research is global, why some countries approve trials quicker, why patients in developing economies need to have access to these trials, how countries differ with their regulatory requirements, and the hottest topics in compliance. Learn more at CaptainIntegrity.com
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The best defense is a good offense. In this episode, Captain Integrity Bob Wade discusses the dreaded UPICs (Unified Program Integrity Contractors) with Harriett Wall, President & CEO of LW Consulting. Hear why a UPIC audit is a very serious matter, why you need to organize your team as soon as possible, how to put together a robust compliance plan, who could be the subject of a UPIC audit, and how the appeal process works. Learn more at CaptainIntegrity.com
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Attackers only win when you have no choice left. In this episode, Captain Integrity Bob Wade breaks down the importance of cybersecurity in healthcare & compliance with Matthew Toussain, Founder of Open Security. Hear how to focus on the basics, why you shouldn’t trust anyone, how to know your risk and the enemy, how to stay ahead of cybersecurity attacks, and Matthew’s background in the Air Force. Learn more at CaptainIntegrity.com
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AI in healthcare is moving at a pace we’ve never seen. In this episode, Captain Integrity Bob Wade explores the fascinating future of AI (Artificial Intelligence) in healthcare with David Norris, Co-Founder & CEO of Affineon Health. Hear why you should embrace AI as a healthcare provider, why this is the most transformative time for healthcare providers, how AI will significantly shift responsibility, how AI can help reduce burnout in the healthcare industry, and the top use cases for AI in healthcare. Learn more at CaptainIntegrity.com
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Compliance programs matter. In this episode, Captain Integrity Bob Wade discusses the DOJ Civil/Criminal Updated Enforcement Plan with Jillian Willis, Partner at Nelson Mullins. Hear how the DOJ (Department of Justice) is committed to investigating & prosecuting white-collar crime, how the Corporate Whistleblower Awards Pilot Program incentivizes whistleblowers, why compliance programs still matter in each administration, the overlap between criminal & civil protocols, and all the latest updates to the DOJ’s enforcement plan. Learn more at CaptainIntegrity.com
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Wondering how the One Big Beautiful Bill will impact healthcare if it passes the Senate? In this episode, Captain Integrity Bob Wade shares all you need to know. Hear how a substantial number of Medicaid beneficiaries would lose their status, how rural hospitals could reopen, why the annual increases in the Medicare conversion factor will decrease, the most important takeaways Bob learned while reading the bill, and the biggest differences vs. the current law. Learn more at CaptainIntegrity.com
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Are there ethical considerations in physician compensation arrangements? In this episode, Captain Integrity Bob Wade explains why the answer is a resounding YES. Hear the difference between ethics, compliance, and integrity, why physician compensation models could cause physicians to conduct themselves in an unethical manner, the value society has placed on different occupations, a variety of examples from the healthcare industry, and the client question that sparked this episode idea. Learn more at CaptainIntegrity.com
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Is timely and accurate completion of medical records all about the money? In this episode, Captain Integrity Bob Wade explains why there’s a whole lot more involved. Hear how medical records impact reimbursement and more, how they help establish the physician from a quality standpoint, how they allow for continuity between subsequent providers, the biggest issue when it comes to medical records, and an original poem from Captain Integrity. Learn more at CaptainIntegrity.com
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What keeps you up at night in compliance? That’s the question Captain Integrity Bob Wade asks several compliance officers in this episode, recorded from the HCCA’s 29th Annual Compliance Institute in Las Vegas. Hear why you should go to conferences, the biggest concerns compliance officers have today, why we should be more open about compliance, the wide variety of compliance professionals & healthcare organizations that attend the Compliance Institute, and the most surprising compliance issues to watch out for. Learn more at CaptainIntegrity.com
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Can you charge a payer lower than Medicare or Medicaid? In this episode, Captain Integrity Bob Wade explores when you can, and when you can’t. Hear why you need to look for the average or median of all expected payments, why you should remove the low and extravagant charges, how Medicare is not entitled to the lowest price you charge anyone, the origin of the most favored nation clause, and some fun customs we see in society. Learn more at CaptainIntegrity.com
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What’s a referral under the Stark Law and Anti-Kickback Statute (AKS)? In this episode, Captain Integrity Bob Wade dives into the definition. Hear what defines a referral, the 3 specialties that don’t refer, why a referral under the AKS is much broader in comparison with the Stark Law, the history of a famous saying, and the value of a memorable slogan. Learn more at CaptainIntegrity.com
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In Fiscal Year 2024, the federal government collected $2.9 billion in False Claims Act settlements (FCA). In this episode, Captain Integrity Bob Wade explains what happened. Hear how the qui tam bar is still active, why Stark Law and Fair Market Value issues (FMV) are still very big issues for compliance, how the Department of Justice (DOJ) gives you credit for cooperation & self-reporting, a deep dive into the numbers from 2024, and some fun facts about the settlements. Learn more at CaptainIntegrity.com
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There are critical steps you need to take if you’re issued a Civil Investigative Demand (CID). In this episode, Captain Integrity Bob Wade explains how it works & what to do. Hear what happens if you fail to respond to a CID, why a legal hold is a must, how to be organized when submitting the documents, the difference between a CID and a subpoena, and some Fig Newtons nostalgia. Learn more at CaptainIntegrity.com
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Hospital-employed physicians can be investors in Ambulatory Surgery Centers (ASCs). In this episode, Captain Integrity Bob Wade wraps up his breakdown of ASCs. Hear what needs to happen for a physician to invest with a hospital in an ASC, why any items or services provided must be consistent with the safe harbors, how the Hospital-Physician ASC works, how many one-third income tests are needed, and a recap of the main takeaways with ASCs. Learn more at CaptainIntegrity.com
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All safe harbors require the one-third income test. In this episode, Captain Integrity Bob Wade continues his breakdown of Ambulatory Surgery Centers (ASCs). Hear how the one-third income test works, when a second one-third test is needed, what the Return on Investment (ROI) needs to be based on, the 4 types of ASCs safe-harbored under the Anti-Kickback Statute (AKS), and how to approach loans. Learn more at CaptainIntegrity.com
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In the case of Ambulatory Surgery Centers (ASCs), the Stark Law does not apply. In this episode, Captain Integrity Bob Wade kicks off his breakdown of ASCs. Hear the pros & cons of ASCs from a patient’s perspective, why the Stark Law does not apply, why ASCs need to be billed under the composite rate, how block booking works for physicians, and the story of Bob’s daughter’s ACL. Learn more at CaptainIntegrity.com
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You don’t have to accept what is given to you. In this episode, Captain Integrity Bob Wade dives into Medicaid reimbursement litigation with Knicole Emanuel, Partner at Nelson Mullins. Hear why litigation is an option to fight low Medicaid rates, why you don’t need to accept the reimbursement rates presented, how medical equity works, the David vs. Goliath case Knicole worked on, and some examples in terms of children’s dental needs. Learn more at CaptainIntegrity.com
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The Comp RVU is not the same as the wRVU. In this episode, Captain Integrity Bob Wade continues his discussion on wRVUs & more with Matt BonDurant, Co-Founder & SVP at ProCARE. Hear why Comp RVUs and wRVUs both have complexities, why everyone is handling it differently, the fundamental problem in the industry, examples of modifiers, and who is involved with Comp RVUs. Learn more at CaptainIntegrity.com
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There’s a lot to consider when it comes to RVUs (Relative Value Units). In this episode, Captain Integrity Bob Wade breaks down wRVUs & more with Matt BonDurant, Co-Founder & SVP at ProCARE. Hear what a Comp RVU is, the nuts & bolts of RVUs, why RVUs are so complicated, how to approach benchmark data, and Bob’s story from Philmont Scout Ranch. Learn more at CaptainIntegrity.com
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The 29th Annual Compliance Institute is not to be missed. In this episode, Captain Integrity Bob Wade gives a preview for the conference - which takes place on April 28-May 1, 2025 at the ARIA Resort & Casino in Las Vegas - with Dan Roach, Interim CEO of HCCA (Health Care Compliance Association). Hear what the HCCA does, why the 29th Annual Compliance Institute is a great opportunity to expand your network, the value of in-person conferences on compliance, why compliance education is so important, and the history of Dan & Captain Integrity at the conference. Learn more at CaptainIntegrity.com
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Pooled compensation models are legal. In this episode, Captain Integrity Bob Wade discusses the compliance & legal risks when it comes to pooled compensation models. Hear how to make sure the units going into the pool are Fair Market Value (FMV), how to carefully select pool participants, how the compensation should be divided, Bob’s swimming pool analogy, and some trivia about Two-Face from Batman. Learn more at CaptainIntegrity.com
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With seemingly more & more whistleblowers every day, it’s becoming that much more important to monitor physician compensation arrangements. In this episode, Captain Integrity Bob Wade shares the best practices for oversight of physician compensation arrangements. Hear why it’s all about process, it’s also about documentation, it’s important to obtain good advice from lawyers & consultants, recent examples of whistleblowers, and the perks of having an open door for feedback. Learn more at CaptainIntegrity.com
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When is the violation of the Anti-Kickback Statute a False Claims Act liability? In this episode, Captain Integrity Bob Wade explains the scenario given a recent district court decision. Hear how the “But For” Causation Standard works under the False Claims Act (FCA) and Anti-Kickback Statute (AKS), how the language has changed under the Anti-Kickback Statute, why the issues brought forward were bifurcated, how sales reps played into the decision, and an analogy involving roller coasters & Cedar Point. Learn more at CaptainIntegrity.com
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Drumroll, please! In this episode, Captain Integrity Bob Wade announces the 2024 “Winners” for Most Egregious US Healthcare Profiteering. Hear why patient care should always be over profits for organizations, why medical necessity is still a primary issue we should be concerned about, why you shouldn’t sell body parts until you get consent, why the award’s named after Martin Shkreli, and Bob’s fandom of “The King of the Countdown” Casey Kasem and the American Top 40 growing up. Learn more at CaptainIntegrity.com
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Not every entity that touches a Designated Health Service is deemed to be a DHS entity as defined under the Stark law. In this episode, Captain Integrity Bob Wade explains why. Hear how a DHS entity is determined, how physicians can still be owners of entities that touch a DHS, what happens if an entity is under arrangement, the 2 major categories of DHS entities, and an example involving Tesla. Learn more at CaptainIntegrity.com
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We have a system that is not geared to ensure we get the healthcare we need. In this Part 2, Captain Integrity Bob Wade continues his discussion of The Big Lie in My Healthcare Bill: Why I Don’t Owe What My Insurer Fails to Pay with Author Frank Lobb. Hear the average error amount in a healthcare bill, how fighting a healthcare bill can impact your credit score, who you should fight in the event of an incorrect healthcare bill, the hidden contract at the core of everything, and what makes Frank’s book different. Learn more at CaptainIntegrity.com
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Many episodes of Stark Integrity have been focused on healthcare providers. This one is for patients. In this episode, Captain Integrity Bob Wade dives into The Big Lie in My Healthcare Bill: Why I Don’t Owe What My Insurer Fails to Pay with Author Frank Lobb. Hear how Frank became interested in the healthcare billing issue, how healthcare billing works, why the healthcare industry & insurance are so out of control, what to do if your insurer denies paying for your healthcare, and the details of the contracts. Learn more at CaptainIntegrity.com
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Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” “Jolly OIG Agent,” and “The 12 Days of Compliance.” Share the poems with your team and learn more at CaptainIntegrity.com
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Want to know what you get for The 12 Days of Compliance? In this special holiday episode, Captain Integrity Bob Wade reflects on 2024 and sings his latest custom Stark Law holiday carol, “The 12 Days of Compliance.” Hear the latest from Bob’s personal life & Nelson Mullins, his favorite things to do in Nashville, the history of “The Twelve Days of Christmas,” fun facts about the birds in the song, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com
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If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck. In this episode, Captain Integrity Bob Wade shares how The Duck Test relates to wRVUs (work Relative Value Units) with Eric Leafgreen, VP of Provider Compensation at Ludi. Hear how to stabilize with oversight, how to embrace simplification through standardization, why you should do an annual check-up, the most overlooked areas that can lead to inaccuracies, and the origin of The Duck Test. Learn more at CaptainIntegrity.com
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During the 1st half of 2024, the Department of Justice’s enforcement activity collected over $1 billion. In this episode, Captain Integrity Bob Wade shares the focus of those DOJ settlements. Hear how the government is still collecting large settlements from providers, how qui tam relators are still bringing these cases to fruition, the importance of having an effective compliance program, the most notable settlements from the 1st half of 2024, and a particular settlement compliance officers will need to “hold their hats for.” Learn more at CaptainIntegrity.com
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Use the data early & often. In this episode, Captain Integrity Bob Wade explores the intersection of data analytics & the False Claims Act (FCA) with Mandy Asgeirsson, Director at BRG (Berkeley Research Group). Hear why it’s really helpful to understand the data available in an FCA investigation, how to be creative in how you use the data to understand the case or allegations against you, why you should use the data proactively instead of just reactively, how data helps to tell the story, and a case where the data analytics shocked Mandy. Learn more at CaptainIntegrity.com
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Physician space sharing could be a great strategy - if you follow the rules. In this episode, Captain Integrity Bob Wade discusses physician space sharing as it relates to Stark Law compliance with Mike Vetter, Partner at HMS Valuation Partners. Hear why utilizing space sharing arrangements is a very cost-effective strategy for a healthcare system to expand services to other communities, why it starts with communication, why these arrangements are watched by the CMS (Centers for Medicare & Medicaid Services) and the regulatory language set forth, the biggest pitfalls of these types of arrangement, and the hotel room example. Learn more at CaptainIntegrity.com
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Quality will always matter. In this episode, Captain Integrity Bob Wade discusses quality physician compensation as it relates to the Stark Law with Luis Argueso, Co-Founder & Partner at InHealth Advisors. Hear why quality matters, how to translate that importance of quality into effective incentives for healthcare providers, why there’s a lot of opportunity for innovation in this space, how quality relates to Fair Market Value (FMV), and some “stupid dad jokes” from Bob. Learn more at CaptainIntegrity.com
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This is a fascinating moment in the history of the world. In this episode, Captain Integrity Bob Wade discusses social media and the online world as it relates to healthcare providers and the Stark Law with Mark Weinstein, Author of “Restoring Our Sanity Online” and Speaker of the hit TEDx talk, “The Rise of Surveillance Capitalism.” Hear why Big Tech is driving us mad and we have to get it fixed in a hurry, key lessons we can apply to other industries from Big Ag, Big Energy, and Big Tech, how web platforms can succeed while rejecting horrible practices, how to navigate AI (Artificial Intelligence) as a healthcare provider, and what the early days of social media were like. Learn more at CaptainIntegrity.com
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What do The Addams Family, 1960s, OIG Agents, Medicare, and Halloween have in common? In this special Halloween episode, Captain Integrity Bob Wade explains the connection as it relates to the Stark Law. Hear all the ‘60s nostalgia you can handle, the history of The Addams Family and creator Charles Addams, the potential for a Captain Integrity TV show, the history of Medicare, and Bob’s special Halloween poem (sung to the tune of The Addams Family), “The Halloween OIG Agents.” Email Bob to get a printed copy of the poem and learn more at CaptainIntegrity.com
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Oh no - the dreaded overpayments. In this episode, Captain Integrity Bob Wade explores overpayment notices, mistakes, and the appeal process with Knicole Emanuel, Partner at Nelson Mullins. Hear why tentative notices of overpayments are scary but defensible, why you should know your right to appeal, the potential changes coming that may be in the providers’ best interest, why you should have some legal assistance through this process, and the alphabet soup of acronyms. Learn more at CaptainIntegrity.com
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Is there such a thing as a free lunch in healthcare? In this episode, Captain Integrity Bob Wade gives you the rules, regulations, and requirements as it relates to the Stark Law. Hear why there’s no such thing as a free lunch, what you can do when there are service deficiencies, how to approach providing technology, recent cases that involve free lunches, and the history of free lunches. Learn more at CaptainIntegrity.com
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“Bob, I think we have a big problem on our hands.” In this episode, Captain Integrity Bob Wade continues his discussion of the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear how to act with integrity, know when a case should be bifurcated, revamp your compliance program, why the DOJ got involved, and why the saga continues with this case. Learn more at CaptainIntegrity.com
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And it all started with a Fair Market Value (FMV) defensibility analysis. In this episode, Captain Integrity Bob Wade discusses the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear why there should be heightened scrutiny with a Lone Wolf, why you need to pay special attention to a high producer, why most of the services a specialist provides should be in their specialty, the most shocking findings from the case, and Bob’s role in the case. Learn more at CaptainIntegrity.com
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Let’s go Back to the Future. In this episode, Captain Integrity Bob Wade “time travels” to all things Chevron deference with Phillip Mullinnix, Partner at Nelson Mullins. Hear why prior court rulings are up for grabs, where to expect more litigation, where to expect lengthy legislation, the history of the Chevron case, and some Back to the Future movie trivia. Learn more at CaptainIntegrity.com
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Emails are evil. In this episode, Captain Integrity Bob Wade explores the new compliance risk of algorithmic pricing with fan-favorite Bart Daniel, Partner at Nelson Mullins. Hear why you should beware of algorithmic pricing, beware of Private Equity (PE), examine the reimbursement rates closely, how to turn your expense department into a revenue department, and why enforcing algorithmic pricing is a top priority. Learn more at CaptainIntegrity.com
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The Improbable Day or Impossible Day is a major compliance issue. In this episode, Captain Integrity Bob Wade chats these scenarios with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to avoid an Improbable Day or Impossible Day scenario, why you should do scheduling audits, why the best defense is a strong offense, the biggest red flags with these scenarios, and a little Tom Cruise and Sherlock Holmes. Learn more at CaptainIntegrity.com
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Data is endlessly impactful in the healthcare space. In this episode, Captain Integrity Bob Wade discusses open payments and compliance findings with Aaron Narva, Co-Founder and CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts in your organization, how your data is available and under scrutiny, why understanding your data can be your secret weapon, some staggering numbers from The Open Payments Report, and how commercial reasonableness (CR) plays into healthcare payments. Learn more at CaptainIntegrity.com
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A referral by a physician of a Designated Health Service (DHS) is the key to opening up the Stark Law City. In this episode, Captain Integrity Bob Wade explains what a DHS is and how they’re categorized. Hear why you should add the CMS (Centers for Medicare & Medicaid Services) website page about the Stark Law to your Favorites, which Stark Law categories are defined by the CPT/HCPCS code, the scenarios where the Stark Law doesn’t apply, what defines a DHS, and the time Captain Integrity got the Key to the City. Learn more at CaptainIntegrity.com and email Bob to get the slide
Move it to an asset rather than a liability. In this episode, Captain Integrity Bob Wade talks Corporate Integrity Agreements (CIAs) and Independent Review Organizations (IROs) with Harriett Wall, President and CEO of LW Consulting, Inc. Hear how to avoid CIAs with a strong compliance program, why an IRO should be open to input, how to embrace a CIA for change, whether an OIG Monitor (Office of Inspector General) is a friend or foe, and a Lion King reference from Captain Integrity. Learn more at CaptainIntegrity.com
Data is a big driver of a lot of cases. In this episode, Captain Integrity Bob Wade breaks down the press release and results from the Criminal National Health Care Fraud Enforcement Action in 2024 with Jillian Willis, Partner at Nelson Mullins. Hear how data analytics remain at the forefront of detecting and prosecuting healthcare fraud, why criminal healthcare fraud enforcement remains a priority for the DOJ (Department of Justice), the importance of having a good culture of compliance, what is considered fraud, and when healthcare fraud is considered a crime. Learn more at CaptainIntegrity.com
Monitoring is a crucial piece of compliance. In this episode, Captain Integrity Bob Wade discusses documenting monitoring efforts with James Rose, Managing Director of SunHawk Consulting. Hear how to provide an annual attestation of compliance, how to build controls and oversight into the business, the difference between auditing and monitoring, where to start when it comes to monitoring, and the biggest monitoring mistakes that occur today. Learn more at CaptainIntegrity.com
Crises happen all the time. In this episode, Captain Integrity Bob Wade talks next generation root cause analysis with James Rose, Managing Director of SunHawk Consulting. Hear why you should never let a good crisis go to waste, follow up on big near-misses, look at root cause analysis from multiple angles, the background behind root cause analysis, and the biggest mistakes in Six Sigma analysis. Learn more at CaptainIntegrity.com
What was the Correlation Theory under the Stark Law? In this episode, Captain Integrity Bob Wade explains what it was and how it differs from the Volume or Value Varying Standard and Volume or Value Determination Standard. Hear why the Correlation Theory is dead, when it can still be a valid theory, what to focus on when it comes to Volume or Value, what happened in the Bookwalter case, and some of the most common conspiracy theories and math theories. Learn more at CaptainIntegrity.com
Compensating Key Opinion Leaders (KOLs) or thought leaders is a little different than regular physician compensation. In this episode, Captain Integrity Bob Wade walks you through how to evaluate KOL compensation. Hear why not every physician is a KOL, why you need to look at the services requested to be performed, how everything boils down to an hourly rate, the importance of the market, and Captain Integrity’s hobby of bird-watching. Learn more at CaptainIntegrity.com
Are percentage-based compensation arrangements permitted under the Stark Law? In this episode, Captain Integrity Bob Wade explores the answer. Hear the circumstances where percentage-based compensation arrangements are permissible, why they’re prohibited when it comes to office space or equipment rentals, the difference between percentages and percentage points, the most common exceptions where percentage-based compensation arrangements are used, and a poem read by Captain Integrity himself. Learn more at CaptainIntegrity.com
To per-click or not to per-click? That is the question. In this episode, Captain Integrity Bob Wade breaks down all things per-click arrangements under the Stark Law. Hear why per-click arrangements are permissible under limited circumstances, how it works with lessors and lessees, what you can bundle together, the most common misconceptions about per-click arrangements, and everything from Shakespeare to Sesame Street. Learn more at CaptainIntegrity.com
It’s an evolving industry. In this episode, Captain Integrity Bob Wade breaks down compensation learnings from the AAPCP (American Association of Provider Compensation Professionals) Annual Conference with Chris Fete, Partner at Pinnacle Healthcare Consulting (PHC). Hear why the growth and involvement of AAPCP is important for the industry, why the AAPCP credential is a good thing, how to stay on top of trends, what to think of AI in the healthcare space, and some fun perks of this year’s conference in Nashville. Learn more at CaptainIntegrity.com
How do you identify covert retaliation? In this episode, Captain Integrity Bob Wade reveals 8 categories of covert retaliation as they relate to the Stark Law. Hear the 2 broad categories of retaliation, how the anti-retaliation provisions under the False Claims Act (FCA) are separate causes of action an individual can bring against entity and individuals, why covert retaliation is the most challenging form of retaliation to identify, the origins of retaliation, and how it differs when it comes to government employees. Learn more at CaptainIntegrity.com
Billions of dollars are spent on marketing in the healthcare sector each year. In this episode, Captain Integrity Bob Wade explains why such marketing can cause issues under the Stark Law and Anti-Kickback Statute (AKS). Hear why marketing between referral sources is not illegal, you need to look at the development and placement of the advertisement, Fair Market Value (FMV) is king, the typical amount different medical specialties spend each month on marketing, and the different types of ads you can run. Learn more at CaptainIntegrity.com
Does the Stark Law have a de minimis compensation exception? In this episode, Captain Integrity Bob Wade explores whether one exists. Hear what a de minimis compensation exception means, why the compensation must still be Fair Market Value (FMV) and Commercially Reasonable (CR), why you don’t need to have a written agreement after the fact, examples from the world of the Stark Law, and a brief history lesson on exceptions. Learn more at CaptainIntegrity.com
Understanding a wRVU (work Relative Value Unit) might feel like searching for the Holy Grail. In this episode, Captain Integrity Bob Wade explains what a wRVU is. Hear why you need to understand what a wRVU is, why work effort is a component, how to avoid the pitfalls with wRVUs, some of the many acronyms in the healthcare industry, and a classic Monty Python story. Learn more at CaptainIntegrity.com
The Volume or Value Restriction under the Stark Law is a conundrum. In this episode, Captain Integrity Bob Wade breaks down how to approach compensation under the Stark Law. Hear why aggregate compensation can vary, why you can use the same analysis under the safe harbors under the Anti-Kickback Statute (AKS), why you should keep your compensation determination process separate, how volume and value are determined, and when to use volume or value. Learn more at CaptainIntegrity.com
Telehealth is here to stay. In this episode, Captain Integrity Bob Wade continues his discussion on telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how to think through which encounters would benefit from telehealth, why consent is so important, why prevention is key, the guidance on coding and billing, and what the future of telehealth will look like. Learn more at CaptainIntegrity.com
Telehealth should be a service that is used to diagnose and treat a patient. In this episode, Captain Integrity Bob Wade talks telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how telehealth works, new legislation that affects telehealth, compliance risks associated with telehealth, how Christine’s love for telehealth goes back to The Jetsons, and some fun stories from the conference in Alaska. Learn more at CaptainIntegrity.com
Make sure documentation related to physician financial arrangements helps you, not hurts you. In this episode, Captain Integrity Bob Wade shares how this documentation can work to your advantage. Hear why training is critical, why you should look at your documentation through the eyes of the Department of Justice (DOJ), Officer of Inspector General (OIG), or a qui tam relator, how to do periodic audits or reviews, who to include on emails, and how to know the waters of the negotiating pool. Learn more at CaptainIntegrity.com
The DOJ (Department of Justice) collected $2.68 billion under the False Claims Act (FCA) in Fiscal Year 2023. In this episode, Captain Integrity Bob Wade recaps the latest interesting stats from FCA settlements. Hear why the FCA is still a very vital weapon for the government to pursue fraud, how healthcare made up 67% of the FCA settlements in Fiscal Year 2023, qui tam relators brought 86% of settlements, other record-setting numbers from the year, and a nod to Carl Sagan’s Billions & Billions. Learn more at CaptainIntegrity.com
Fair Market Value (FMV) and Commercial Reasonableness (CR) are separate concepts, but overlap. In this episode, Captain Integrity Bob Wade talks all things FMV vs. CR. Hear why CR is not one of value, it has 2 components, where the overlaps exist, Bob’s pie analogy, and what factors to consider. Learn more at CaptainIntegrity.com
Under the Stark Law, entities with medical staffs can pay for treatment and promotion of mental health. In this episode, Captain Integrity Bob Wade dives into the tough topics of substance abuse and addiction as they relate to the Stark Law. Hear why we’re all addicted to something, the new exception under the Stark Law, why the exception is a good thing, the 5 characteristics of an addiction, and which medical profession has the highest burnout rate. Learn more at CaptainIntegrity.com
Commercial Reasonableness is like a pie. Fair Market Value (FMV) is like a slice of the pie. In this episode, Captain Integrity Bob Wade discusses the latest on FMV under the Stark Law with Tim Smith, Principal at TS Healthcare Consulting. Hear why you need to study the regs, start doing economic analysis, start developing in-house expertise in this area, what you need to say loudly and clearly, and insights from Tim’s book, “The Complete Guide to Fair Market Value Under the Stark Regulations.” Learn more at CaptainIntegrity.com
If you’re able to meet in the middle, you can share the risk. In this episode, Captain Integrity Bob Wade covers employing hospital-based specialists with Joe Aguilar and Natalie Bell, Partners at HMS Valuation Partners. Hear why you need to do the math, you should consider sharing the risk, what happens once you take the leap, how to determine the stipend, and revenue cycle management. Learn more at CaptainIntegrity.com
Look at your policies and make sure they’re up to date. In this special episode, Captain Integrity Bob Wade wraps up his discussion on insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 3 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on January 9, 2024. Hear “The WOW Factor,” when you need to look at commercial reasonableness, whether pay bumps are justified, why fundamental economics are so important, and when to get a second opinion. Email Bob to get the slides and learn more at CaptainIntegrity.com
You need to make sure you’re providing accurate information. In this special episode, Captain Integrity Bob Wade continues his discussion on insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 2 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on January 9, 2024. Hear the key allegations, why you need to read the evaluation report thoroughly, the different specialties included in the settlement, how benchmarking plays into things, and the “Garbage In, Garbage Out” philosophy. Email Bob to get the slides and learn more at CaptainIntegrity.com
A complaint is just a complaint. In this special episode, Captain Integrity Bob Wade discusses insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 1 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on January 9, 2024. Hear the timeline of the settlement, the unique elements of the case, Bob’s car-buying analogy, The Golden Rule, and why different firms differ on Fair Market Value (FMV). Email Bob to get the slides and learn more at CaptainIntegrity.com
If you have bad news to share, you share it yourself - and own it. In this episode, Captain Integrity Bob Wade discusses crisis communication management with Eileen Wixted, Principal at Wixted & Co. Hear why it’s all about how you respond, why it’s important to be truthful, how to build trust through communication, the different types of crises, and how to determine a communication strategy. Learn more at CaptainIntegrity.com
You’re more powerful than you think. In Part 2 of this special interview, Captain Integrity Bob Wade continues his discussion of one of the most infamous compliance stories in recent history with Frances Haugen, the Facebook whistleblower, Founder of Beyond the Screen, and Author of “The Power of One.” Hear how your life might change once you became a whistleblower, whether it’s worth it, her advice to employees who discover unethical behavior, the pros and cons of holding a secret, and how to hold organizations accountable. Learn more at CaptainIntegrity.com
Be ethical. In this special episode, Captain Integrity Bob Wade breaks down one of the most infamous compliance stories in recent history with Frances Haugen, the Facebook whistleblower, Founder of Beyond the Screen, and Author of “The Power of One.” Hear her experiences and challenges being a whistleblower, how she lost her job but gained respect, what to do if you see something unethical, how the structure at Facebook (now Meta) worked, and what happens when you put things in writing. Learn more at CaptainIntegrity.com
Be careful what you put in writing. In this special episode, Captain Integrity Bob Wade discusses the recent General Compliance Program Guidance (GCPG) issued by the OIG (Office of Inspector General) with Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 2 of a 2-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on November 16, 2023. Hear the questions and issues the OIG has offered, when Fair Market Value (FMV) becomes irrelevant, why emails are evil, the manner in which remuneration is determined, and why you need to be careful with deals with family members of physicians. Email Bob to get the slides and learn more at CaptainIntegrity.com
Mitigate your risk. In this special episode, Captain Integrity Bob Wade discusses the recent General Compliance Program Guidance (GCPG) issued by the OIG (Office of Inspector General) with Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 1 of a 2-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on November 16, 2023. Hear the history of the OIG issuing guidance, why you need to follow their guidance, how to mitigate risk, the 7 elements from the OIG, and Bob’s traffic cop analogy. Email Bob to get the slides and learn more at CaptainIntegrity.com
Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” and “Jolly OIG Agent.” Share the poems with your team and learn more at CaptainIntegrity.com
Thank you, listeners, for making this 100th episode of Stark Integrity happen. In this special milestone and holiday episode, Captain Integrity Bob Wade reflects on 2023 and reads his latest custom Stark Law holiday poem, “Jolly OIG Agent.” Hear what Bob is grateful for in 2023, his latest thoughts on the Stark Law, the history of a certain controversial holiday poem, what to expect next from Stark Integrity, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com
A chair is more than a chair. In this episode, Captain Integrity Bob Wade dives into fixed asset valuations under the Stark Law with Mike Vetter, Partner at HMS Valuation Partners. Hear why valuations in healthcare have additional regulatory guidelines and laws to follow, the devil is in the details, using a certified appraiser with healthcare experience can help keep you compliant, the weirdest fixed assets Mike has had to value, and what The Wizard of Oz has to do with fixed asset valuations. Learn more at CaptainIntegrity.com
There’s going to be more and more competition in the healthcare space. In this episode, Captain Integrity Bob Wade discusses recruitment and the Physician Needs Assessment (PNA) as it relates to the Stark Law with Coker Group VP Stephen Ross and EVP Justin Chamblee. Hear why there will be a continued strain on organizations to provide access to high-quality healthcare, why you need to use and regularly update a PNA in order to confirm Commercial Reasonableness (CR), how the value of the PNA extends to supporting and informing growth of service lines and other health system initiatives, the latest trends in the workforce, and how to successfully recruit physicians while remaining in compliance. Learn more at CaptainIntegrity.com
There are a multitude of compliance issues related to medical directors. In this episode, Captain Integrity Bob Wade explains why there’s a struggle, yet they’re so important. Hear why you need to evaluate the commercial reasonableness (CR) of the medical director administrative arrangement, how to determine the hourly rate using clinical benchmark data, how to verify the services and hours are reasonable when the time records are available, famous Stark Law cases involving medical directors, and the key questions to ask when considering compensation. Learn more at CaptainIntegrity.com
Why are there timing requirements under the Stark Law? In this episode, Captain Integrity Bob Wade explores the background and details of these limitations. Hear why the 1-year term is a standalone provision under the exception, when the calendar year vs. a rolling period applies, why you should be careful about the multiple use of various exceptions, how timing limitations are determined, and an original poem for this episode. Learn more at CaptainIntegrity.com
There are a ton of considerations when it comes to hospital-based financial arrangements under the Stark Law. In this episode, Captain Integrity Bob Wade goes into the numbers and details with Joe Aguilar, Partner at HMS Valuation Partners. Hear why it’s important to include all aspects of revenue when determining Fair Market Value (FMV), why you need to understand the Full-Time Equivalents (FTEs), why you shouldn’t be afraid to start considering building the service line in house, why the devil is in the details, and Joe’s additional experience as a nurse practitioner. Learn more at CaptainIntegrity.com
A master list reference is sometimes necessary under the Stark Law. In this episode - suggested by a Stark Integrity listener - Captain Integrity Bob Wade explains when and why that’s the case. Hear why creating a master list is just good practice, why it’s a legal requirement to cross-reference it, why you need to dedicate resources to maintain a master list, some interesting numbers tied to master lists, and what The Sound of Music has to do with them. Learn more at CaptainIntegrity.com
When do you need to enter into the Self-Referral Disclosure Protocol (SRDP)? In this episode, Captain Integrity Bob Wade talks the notable settlements and timing under the SRDP. Hear how the CMS (Centers for Medicare and Medicaid Services) is investing greater resources to review and settle these Stark Law violations, why it can be a long process, why it’s advantageous to enter the protocol process, how to do so, and the record-setting numbers tied to the SRDP. Learn more at CaptainIntegrity.com
Hear Captain Integrity Bob Wade perform his original Stark Law Halloween song, “Compliance Mash.” Share the song with your team and learn more at CaptainIntegrity.com
Let’s take a ride through history regarding Fair Market Value (FMV). In this episode, Captain Integrity Bob Wade dives into the key points along the FMV timeline. Hear why it really started in 1991, it’s been guided by key cases and settlements, the definition has continued to be refined up through today, the most important regulations over time, and what the year 1965 has to do with FMV. Learn more at CaptainIntegrity.com
The Stark Law has its own exception related to Academic Medical Centers. In this episode, Captain Integrity Bob Wade explores its application and alternatives. Hear the definition of Academic Medical Centers, where there’s some leeway, why you might not need to meet the exception, direct vs. indirect compensation arrangements, and how research grants impact things. Learn more at CaptainIntegrity.com
It’s very important to monitor provider financial arrangements. In this episode, Captain Integrity Bob Wade dives into the operational challenges that arise. Hear why the biggest source of compliance issues is through the operation of that contract, you can trust but verify, the importance of knowing who your bus drivers are, some examples of the wheels falling off, and an Urban Dictionary shoutout. Learn more at CaptainIntegrity.com
There have been some surprising and some not-so-surprising settlements under the False Claims Act (FCA) so far in 2023. In this episode, Captain Integrity Bob Wade details the most interesting decisions. Hear why the qui tam bar is still extremely active, there appears to be a great focus on the specialty of ophthalmology, Fair Market Value (FMV) and Stark Law issues are still high on the list, the most notable cases, and one that has a shock factor. Learn more at CaptainIntegrity.com
There’s a lot to unpack from all that happened in 2020. In this episode, Captain Integrity Bob Wade dives into the fallout from the CARES Act with Bart Daniel, Partner at Nelson Mullins. Hear what the CARES Act is, the landscape of fraud relating to the CARES Act, why the PPP (Paycheck Protection Program) was abused so commonly, how the government is pursuing those who abused these programs, and who the whistleblower typically is. Learn more at CaptainIntegrity.com
Call arrangements are a hot topic for many entities in the healthcare space. In this episode, Captain Integrity Bob Wade discusses the details with Ashley Graver, Vice President of Coker Group. Hear why organizations should carefully consider the need for each call coverage arrangement, organizations should approach payment for calls in an equitable manner, why you shouldn’t set it and forget it, the type of market data available, and a classic “beeper” reference. Learn more at CaptainIntegrity.com
Civil and criminal investigations have become a huge focus in the healthcare industry. In this episode, Captain Integrity Bob Wade discusses why that’s the case with Bart Daniel, Partner at Nelson Mullins. Hear when you should retain experienced white collar healthcare counsel immediately, how to determine the nature and scope of the investigation, why you should cease any borderline conduct immediately, how an investigation begins, and “The Parade of Horribles.” Learn more at CaptainIntegrity.com
There are several mistakes that can be made when conducting a Fair Market Value (FMV) review. In this episode, Captain Integrity Bob Wade dives into these mistakes and how to prevent them. Hear why FMV opinions are qualified, you should focus on personally performed productivity, how to make sure you understand the full-time equivalency (FTE) of the physician you’re reviewing, the “Dirty Dozen” of FMV analysis mistakes, and how wRVUs fit into the mix. Learn more at CaptainIntegrity.com
How do time-share lease arrangements work in the healthcare world? In this episode, Captain Integrity Bob Wade dives into the details with Ron Young, President and Owner of The Advisory Group. Hear why consistency in your methodology is critical, the monitoring of the space needs to be documented, when to think like a patient, why a hospital or medical provider would time-share real estate, and the hotel room analogy. Learn more at CaptainIntegrity.com
There is a legal storm brewing over the definition of remuneration. In this episode, Captain Integrity Bob Wade breaks down all the factors under the Stark Law. Hear why it needs to meet a safe harbor, it needs to meet Fair Market Value (FMV) and Commercial Reasonableness (CR), why you shouldn’t make the connection between the financial arrangement and the inducement for referrals, notable cases to discuss, and how the transfer of value plays into things. Learn more at CaptainIntegrity.com
Clear, concise, easily understood. In this episode, Captain Integrity Bob Wade discusses the Supreme Court’s ruling on the False Claims Act (FCA) with Bart Daniel, Partner at Nelson Mullins. Hear why no after-the-fact justification can be used to knowingly file a false claim, the subjective standard is the standard, the court made it clear the False Claims Act is rooted in common law fraud, the 3 definitions of knowledge under the False Claims Act, and what drew a Paul Harvey reference from Bart. Learn more at CaptainIntegrity.com
Big changes are coming. In this episode, Captain Integrity Bob Wade continues his discussion of split/shared billing for Advanced Practice Providers (APPs) with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting. Hear how the crediting of wRVUs will be affected, the impact the change will have on measures of productivity, why you should consider changes to provider compensation plans, what it means for compensation for NPPs, and how Fair Market Value (FMV) plays into things. Learn more at CaptainIntegrity.com
It’s going to get confusing. In this episode, Captain Integrity Bob Wade talks split/shared billing for Advanced Practice Providers (APPs) with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting. Hear when the new guidelines go into effect, why the documentation must be substantive, how to correctly identify the date of service, the difference between APPs and NPPs, and what this all means for split/shared visits. Learn more at CaptainIntegrity.com
Is the knowledge requirement under the False Claims Act (FCA) objective or subjective? In this episode, Captain Integrity Bob Wade dives into the murky waters. Hear why the fines and penalties if the FCA applies are huge, murky regulations could be a defense under the FCA, why you should continue to operate as if the subjective factors would apply, the highlights from recent FCA cases, and the origin of the FCA. Learn more at CaptainIntegrity.com
Incorporating Advanced Practice Providers (APPs) has many benefits and risks. In this episode, Captain Integrity Bob Wade lays out those compliance risks and safeguards. Hear the 4 components of the quadruple aim, why you need documentation for incident-to and split/shared visits, how to handle credit given to any physician for the wRVUs performed by the APP, who’s considered an APP, and the discussion point in which Bob might be stepping into quicksand. Learn more at CaptainIntegrity.com
The Eliminating Kickbacks in Recovery Act (EKRA) is a huge statute. In this episode, Captain Integrity Bob Wade discusses the similarities and differences between EKRA and the Anti-Kickback Statute (AKS). Hear why EKRA applies to private payers, there are broader applications under EKRA as opposed to the AKS, how EKRA applies generally to clinical laboratories, the origin of EKRA, and “liquid gold” in the recovery world. Learn more at CaptainIntegrity.com
The Tuomey case is a pinnacle case for healthcare regulatory attorneys. In this episode, Captain Integrity Bob Wade continues his Tuomey case discussion with Bart Daniel, Partner at Nelson Mullins. Hear why you need to take complaints from employees seriously, why you shouldn’t seek a 2nd opinion on Fair Market Value (FMV) and Commercial Reasonableness (CR), how to structure a model that is compliant and defensible, why the government used the Tuomey case as a poster child, and what issues to look for as a compliance officer or general counsel. Learn more at CaptainIntegrity.com
There’s a lot we can learn from the landmark Tuomey case in the healthcare industry. In this episode, Captain Integrity Bob Wade discusses the Stark Law and legal learnings with someone who was involved firsthand in the case: Bart Daniel, Partner at Nelson Mullins. Hear why you shouldn’t dig the hole deeper, why you should take 1 appraisal and stick with it, how to settle a False Claims Act case, why the Tuomey case went down the way it did, and why it ended up being a way bigger case than initially thought. Learn more at CaptainIntegrity.com
Healthcare transactions are different from ordinary transactions. In this episode, Captain Integrity Bob Wade discusses the issues we should be focusing on in the healthcare space. Hear how to ensure the arrangement is Fair Market Value (FMV), why you should purchase assets, when not to assume liability for physicians, the biggest transactional issues in the healthcare space, and when to figure out if the Stark Law applies. Learn more at CaptainIntegrity.com
There’s been a fascinating shift to value-based reimbursement arrangements from those based on production. In this episode, Captain Integrity Bob Wade discusses trends and issues in that space with Christine Worthen, Partner at Nelson Mullins. Hear why you should consider your strategic planning for the glide path to risk, look at the regulatory addendum and negotiate it, always have providers at the table, opportunities within deferred compensation, and how you can mitigate the risk of takebacks. Learn more at CaptainIntegrity.com
Creating a tagline, slogan, or logo could be an effective way to market and promote your compliance program. In this episode, Captain Integrity Bob Wade dives into the marketing of your compliance program. Hear how a logo helps promote the identification of your compliance program, why it should be consistently used, why it doesn’t ensure an effective compliance program on its own, the story of Captain Integrity, and some nostalgia around Schoolhouse Rock! Learn more and check out the white paper at CaptainIntegrity.com
Unfortunate statements and emails can trigger a long and expensive journey for an organization. In this episode, Captain Integrity Bob Wade discusses the Greber and Holland cases as they relate to the One Purpose test with Gabe Imperato, longtime friend and Partner at Nelson Mullins. Hear why the U.S. v. Holland case is a significant decision, the court looked for evidence of willful conduct, the decision exposes the shortcomings of the One Purpose Test, when it’s optimal for the government to apply the One Purpose Test, and why educating your organization on these matters is so important. Learn more at CaptainIntegrity.com
Waiving copays and deductibles has to be performed in a specific manner. In this episode, Captain Integrity Bob Wade details the ins and outs of waiving copays. Hear why the routine waiver of copays and deductibles can be illegal, you can waive them in certain instances, what will cause a claim to be overstated, what exactly a copay waiver is, and examples from recent cases. Learn more at CaptainIntegrity.com
There’s an interesting issue with respect to the amount of the collections in 2022. In this episode, Captain Integrity Bob Wade highlights the learning points from the DOJ (Department of Justice) 2022 False Claims Act (FCA) Settlements and Judgments. Hear why the qui tam bar still represents the largest dollar amount of settlements, individual accountability is still occurring, we’re still seeing classic fraud and abuse issues, the most notable cases and issues, and how the 2022 numbers compare to previous years. Learn more at CaptainIntegrity.com
One of the most effective parts of a compliance program is to have a compliant culture. In this episode, Captain Integrity Bob Wade breaks down how to foster a culture of compliance. Hear why an ethical culture starts at the top, how to understand the culture of an organization, what to do if you believe your organization is making unethical decisions, how to measure the effectiveness of your compliance program, and the infamous examples of Enron and FTX. Learn more at CaptainIntegrity.com
The new rules create new standards that reduce compliance risk. In this episode, Captain Integrity Bob Wade discusses the key issues in value-based arrangements with Kelly Conroy, Principal at Pinnacle Healthcare, and Ed White, Partner at Nelson Mullins. Hear why now is the time to start your value-based care strategy, value-based enterprises can be used as a strategy for providers to leverage their value proposition with payers, it’s time to get a fresh perspective on the healthcare market landscape, where the government will help most, and the “Holy Grail” of arrangements. Learn more at CaptainIntegrity.com
Physicians may believe a test or procedure is medically necessary, but payers make the final determination. In this episode, Captain Integrity Bob Wade details medical necessity and the implications for Stark Law compliance. Hear why payers make the medical necessity determination, patients are in control, we can compensate a physician if the patient desires additional services, what the Medicare payment rules say, and examples from the medical field. Learn more at CaptainIntegrity.com
How do you audit practically? In this episode, Captain Integrity Bob Wade breaks down the Who, What, and How of audit work plan development under the Stark Law. Hear why you shouldn’t do it alone, how to look at the government resources out there, use some type of numerical weighting to assess risks, why auditing isn’t rocket science, and a sausage analogy from Bob. Learn more at CaptainIntegrity.com
Make sure that management fee is in order. In this episode, Captain Integrity Bob Wade talks Corporate Practice of Medicine (CPOM) compliance with Heather Miller, Healthcare Transactional and Regulatory Lawyer at Nelson Mullins. Hear why you need to substantiate the management fee in your paperwork, stick with a flat management fee, check state laws on leasing, how CPOM ties to the Stark Law, and what varies the most by state. Learn more at CaptainIntegrity.com
Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena” and “Rudy the Seasoned Compliance Officer.” Share the poems with your team and learn more at CaptainIntegrity.com
This year has been full of change, and I want to wish you all a great holiday season. In this special holiday episode, Captain Integrity Bob Wade reflects on change in 2022 and reads a custom Stark Law holiday poem, “Rudy the Seasoned Compliance Officer.” Hear the good and bad changes that came about this year, how it feels to attend and speak at in-person conferences again, significant Stark Law changes that took effect this year, the personal and professional life changes Bob is grateful for, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com
Be an expert in your field. In this episode, Captain Integrity Bob Wade talks compliance program development and effectiveness with Steve Sugrue, Chief Compliance Officer of DocGo. Hear why you should hire people smarter than you, always be relentlessly in pursuit of best practices, seriously consider an approach towards ESG (Environmental, Social, and Governance), how big your compliance team should be, and how the delegation process should work. Learn more at CaptainIntegrity.com
Use your superpowers in the field of compliance. In this episode, Captain Integrity Bob Wade talks value creation in the world of compliance with Jerry Shafran, Founder and Chief Executive Officer of YouCompli. Hear how to channel your inner salesperson, simplify, be an instigator of change, what sales and compliance have in common, and the reputation of compliance professionals. YouCompli helps you go from chaos to confidence. Learn more https://hubs.la/Q01rX8Q60
Can we really throw Fair Market Value (FMV) out the window? In this episode, Captain Integrity Bob Wade revisits Value-Based Arrangements with a special focus on mistakes that can be made. Hear why Value-Based Arrangements through the Safe Harbor and the Exception are a beautiful thing, it’s critical the governing body meet regularly and review the criteria, what happens if you don’t meet any of the requirements under the Value-Based Exception under the Stark Law, Bob’s lug nut example, and a bonus 7th Deadly Mistake. Learn more at CaptainIntegrity.com
Believe it or not, the Stark Law involves charitable contributions by physicians and immediate family members. In this episode, Captain Integrity Bob Wade explains the rules of charitable contributions as they relate to the Stark Law. Hear why remuneration plays a key role, charitable contributions cannot be solicited or offered by a physician who takes into account the volume or value of the referral, the Stark Law does involve supporting organizations, fallout from the different phases of regulations, and key comments in the regulations. Learn more at CaptainIntegrity.com
Legal Independent Review Organizations (IRO) are usually required under Corporate Integrity Agreements when physician financial arrangements are involved in the settlement - but you don’t have to use a LIRO in only Corporate Integrity Agreements. In this episode, Captain Integrity Bob Wade breaks down the world of LIROs when it comes to the Stark Law. Hear why a LIRO has to be independent, it doesn’t have to have an adversarial relationship with the company, LIRO services can be provided outside a Corporate Integrity Agreement, who chooses the LIRO, and what determines the level of detail in a review. Learn more at CaptainIntegrity.com
Thorough documentation can go a long way under the Stark Law. In this episode, Captain Integrity Bob Wade continues to dive into the Medicaid-Stark Law pool - this time with special guest Andy Lenobel, Associate General Counsel at Nationwide Children’s Hospital. Hear why you need to show your work, follow your policy, learn to love the endless nature of compliance, Andy’s view from a hospital’s perspective, and what he hears from clients the most. Learn more at CaptainIntegrity.com
Does the federal Stark law apply to state Medicaid reimbursement? In this episode, Captain Integrity Bob Wade outlines why it doesn’t really matter - as he dives into the Medicaid-Stark Law pool. Hear why there’s still an argument whether hospitals violate the federal Stark Law when they submit Medicaid claims, many states still have their own Stark Law statutes and regulations, Fair Market Value (FMV) and Commercial Reasonableness apply regardless of whether the federal Stark Law applies, examples from Bob’s experience in notable cases, and how the Department of Justice (DOJ) has handled the issue in the past few years. Learn more at CaptainIntegrity.com
Determining where a physician’s conduct should be reviewed is a challenging subject. In this episode, Captain Integrity Bob Wade continues his breakdown of Peer Review and Compliance in relation to the Stark Law. Hear why quality can be both a Peer Review and a Compliance issue depending on the severity, fraud issues that impact billing are usually the exclusive domain of the Compliance department, someone needs to assess issues and concerns to determine who is responsible for their review, specific examples to help you determine who reviews each case, and some things physicians have done you wouldn’t believe. Learn more at CaptainIntegrity.com
Physician activities reviewed through the Peer Review process may pose liability under the False Claims Act - including the Stark Law. In this episode, Captain Integrity Bob Wade details how Peer Review and Compliance can work together. Hear how to train your team on Peer Review and Compliance issues, why Peer Review documents can be reviewed by other appropriate individuals in the hospital, how Peer Review issues can simultaneously be a False Claim, the use of the Midas reporting system, and a thrilling book recommendation from Bob. Learn more at CaptainIntegrity.com
Jury trials under the False Claims Act (FCA) can produce very wild outcomes. In this episode, Captain Integrity Bob Wade breaks down what went down in the recent Eli Lilly/Astellas Pharma case. Hear why jury trials under the FCA are extremely rare, there are large jury verdicts, an effective compliance program can reduce or eliminate the risk of going to court, how big a return the government can receive, and how a mistake could be considered fraud. Learn more at CaptainIntegrity.com
The False Claims Act (FCA) continues to be a huge weapon for the government. In this episode, Captain Integrity Bob Wade details the FCA settlements that have happened so far in 2022. Hear why there are still very large settlements that have occurred under the FCA, the knowledge requirement under the FCA is very broad, Corporate Integrity Agreements (CIAs) and Qui Tam Relators were front and center in many of these settlements, the basics of the FCA, and how much of the penalties are coming from the healthcare sector. Learn more at CaptainIntegrity.com
Accountable Care Organizations (ACOs) are truly unique partnerships with the government. In this episode, Captain Integrity Bob Wade welcomes Kelly Conroy of Pinnacle Healthcare Consulting to chat the ins and outs of ACOs as they relate to the Stark Law. Hear why every primary care physician (PCP) should be in an ACO, almost every big commercial carrier has a shared savings component to it, ACOs are good for society, providers, and patients, how Kelly started the first ACO, and what she does in her job. Learn more at CaptainIntegrity.com
How do you respond to a Civil Investigative Demand (CID) issued by the Department of Justice (DOJ)? In this episode, Captain Integrity Bob Wade details what to do and why you shouldn’t freak out. Hear why you should take the CID seriously and cooperate with the DOJ, involve competent outside legal counsel, review the documents prior to producing them to the DOJ, the types of documents the government demands, and Bob’s poem, “How to Respond to a CID.” Learn more at CaptainIntegrity.com
The Office of Inspector General (OIG) has a Self-Disclosure Protocol (SDP) as well, but it’s different than the Centers for Medicare and Medicaid Services Self-Referral Disclosure Protocol (CMS SRDP). In this episode, Captain Integrity Bob Wade shares how to disclose AKS, False Claims and potentially Stark Law violations through the OIG. Hear why the OIG SDP should not be used for strict Stark Law violations, what it can be used for, the multiplier they’ll target, differences vs. the CMS SRDP, and how long the statute of limitations applies. Learn more at CaptainIntegrity.com
If you discover a Stark Law violation, you can self-report it to the Centers for Medicare and Medicaid Services (CMS) through the Self-Referral Disclosure Protocol (SRDP). In this episode, Captain Integrity Bob Wade breaks down what to do when you find out there’s been a Stark Law violation. Hear why you should do your legal research before using the SRDP, reasonable settlements can be negotiated, you should use competent Stark Law legal counsel to assist you, what happens if you lay low and hope no one discovers the Stark Law violation, and possible resolutions outside of the SRDP. Learn more at CaptainIntegrity.com
Continuing Medical Education (CME) is needed, but you need to be careful how you hold these events. In this episode, Captain Integrity Bob Wade shares the positives and watchouts of CME under the Stark Law. Hear why CME is deemed to be remuneration and therefore must comply with the Anti-Kickback Statute (AKS) and Stark Law, Fair Market Value (FMV) for CME can be made by looking at overall expenses and dividing by the number of anticipated attendees, the best way to provide CME is under the Non-Monetary Compensation Exception or avail yourself of the Medical Staff Incidental Benefit Exception but also conform with the annual or per-benefit requirement, the opinion from the Office of Inspector General (OIG), and how much alcohol and entertainment there can be. Learn more at CaptainIntegrity.com
Compliance experts and monitors can be valuable tools and resources in the world of the Stark Law. In this episode, Captain Integrity Bob Wade breaks down the duties and responsibilities of compliance experts and why they can be valuable for organizations. Hear who compliance monitors are generally appointed by, who pays for their services and expenses, why it’s a valuable effort for an organization to voluntarily engage their services, what life is like as a compliance expert, and an analogy to embedded journalists. Learn more at CaptainIntegrity.com
Being a compliance officer can be very challenging and rewarding. In this episode, Captain Integrity Bob Wade answers the questions he gets most often about compliance officers and the Stark Law. Hear why you need a compliance officer, what a compliance officer does, who should be a compliance officer, Bob’s experience as a compliance officer, and a fun analogy from Toy Story. Learn more at CaptainIntegrity.com
Time reports are important for compliance, Fair Market Value, commercial reasonableness, and cost reporting for physician administrative services. In this episode, Captain Integrity Bob Wade details why time reporting is so essential to Stark Law compliance. Hear why time studies are required for cost reporting purposes, to meet commercial reasonableness and Fair Market Value standards, how to follow the defensibility spectrum, when to get written documentation, and some fun time examples from the music world. Learn more at CaptainIntegrity.com
Compensation pools are commercially reasonable but must be carefully assessed. In this episode, Captain Integrity Bob Wade shares a Stark Law analogy perfect for the summer pool season. Hear why the funding of pooled compensation must come from a defensible source, you cannot use pooled compensation to reward for referrals, attorney and compliance officer “lifeguards” should monitor and audit the division of the pool, the different types of compensation pools, and swimmers with the greatest proficiency. Learn more at CaptainIntegrity.com
K.I.S.S. applies to the Stark Law as well. In this episode, Captain Integrity Bob Wade explains how to “Keep it Simple, Stupid” when considering the Stark Law with your team and clients. Hear how to know your audience, understand what type of complexity you’re dealing with, make your analysis value-based, the impact of attorneys, and how to bring value to your client. Learn more at CaptainIntegrity.com
Providers may be facing a significant workflow change. In this episode, Captain Integrity Bob Wade welcomes Amy Noecker and Zachary Hartsell from SullivanCotter to chat shared services performed by physicians and APPs (Advanced Practice Providers) under the Stark Law. Hear how to assess the current state of split/shared billing, evalue your current care team composition and responsibilities by provider, consider if modifications to compensation arrangements are needed to ensure financial sustainability and regulatory compliance, a breakdown of the time-based methodology, and where things could get problematic. Learn more at CaptainIntegrity.com
It takes two to tango in the Stark Law world. In this episode, Captain Integrity Bob Wade welcomes Marlan Wilbanks, Esq. to chat physician liability and qui tam cases under the Stark Law and Anti-Kickback Statute. Hear why the Fair Market Value (FMV) train runs both ways, you should be very, very wary of how you handle wRVU calculations in your hospital, free employees aren’t always free, why the government is historically so focused on the DHS entities over the physicians, and the formula attorneys like Marlan Wilbanks use when assessing potential qui tam cases. Learn more at CaptainIntegrity.com
It’s time to consider some automation. In this episode, Captain Integrity Bob Wade welcomes Gail Peace of Ludi, Inc. to chat how healthcare technology can make things easier, quicker, and less expensive for your hospital. Hear why automation helps conquer the complex when it comes to the Stark Law, how to make things easier for your physicians, how costly the time you’re spending on manual contracts is, what components to track, and how Gail got into the healthcare industry. Learn more at CaptainIntegrity.com
The parties need to intend to enter into a financial arrangement for a violation under the Stark Law to occur. In this episode, Captain Integrity Bob Wade talks all things “intent” in relation to the Stark Law. Hear why the intent of both parties to enter into an arrangement needs to be made for the Stark Law to be implicated, parties must obtain payment of the value of the remuneration or benefit that has been taken, mere overpayments do not equal a Stark Law violation, Bob’s 3 Buckets of Intention, and how the Anti-Kickback Statute ties into things. Learn more at CaptainIntegrity.com
Hospitals can financially induce non-physician practitioners to relocate - but be very careful. In this episode, Captain Integrity Bob Wade dives into non-physician practitioner recruitment under the Stark Law. Hear why the rules with respect to non-physician practitioners are very different, the financial incentive cannot exceed 50% of the compensation, signing bonus, and benefits, why it’s limited only to primary care and mental health, who the contracts needs to be signed by, and what the pinnacle issue often is. Learn more at CaptainIntegrity.com
We have a chicken and egg problem. In this episode, Captain Integrity Bob Wade welcomes Anthony Domanico of VMG Health to recap what they learned and discussed at the recent AAPCP Conference (American Association of Provider Compensation Professionals). Hear what makes the AAPCP a great organization, why compensation compliance under the Stark Law and Anti-Kickback Statute covers both the amount and structure of the compensation, 2021 wRVU values have an impact that needs to be carefully analyzed, learnings from surveys at the conference, and what tools you can use to develop compensation metrics. Learn more at CaptainIntegrity.com
Under the Stark Law, hospitals can financially induce physicians. In this episode, Captain Integrity Bob Wade continues his analysis on physician recruiting under the Stark Law. Hear why incremental expenses are a major factor with physician recruitment, community need is a requirement for tax-exempt hospitals, you need to monitor these arrangements, the impact of a HPSA (Health Professional Shortage Area), and examples from a few settlements. Learn more at CaptainIntegrity.com
Under the Stark Law, hospitals can financially induce physicians. In this episode, Captain Integrity Bob Wade starts his analysis on physician recruiting under the Stark Law. Hear how to study and apply the strict definitions, why physicians always have to sign the agreement, there’s no Fair Market Value or Commercial Reasonableness requirement specifically stated in the Physician Recruitment exception, how to negotiate a recruitment package, and the bucket analogy. Learn more at CaptainIntegrity.com
How do you know? Where’s the proof? In this episode, Captain Integrity Bob Wade welcomes Lucia Pizano-Urbina of Broward Health to chat about life operating under a Corporate Integrity Agreement and the world of Compliance. Hear how to create a CIA Annual Report Subcommittee, always have a plan of correction for any item, be organized, learn the CIA (Corporate Integrity Agreement) inside and out, and check, check, check. Learn more at CaptainIntegrity.com
If you believe you are a Group Practice, let’s do the Group Practice dance. In this episode, Captain Integrity Bob Wade continues the discussion on Group Practice under the Stark Law. Hear how to know what type of facility in which the services are provided, the difference between ancillary services and incident to services, why multimillion-dollar settlements have occurred in this area, what questions need to be answered, and a recap of Group Practice definitions and subdefinitions. Learn more at CaptainIntegrity.com
Physician fee schedules change frequently. In this episode, Captain Integrity Bob Wade welcomes Bob Madden of SullivanCotter to break down the latest changes in wRVUs and their impact. Hear why you should be very careful when selecting a comparative group from the available benchmark data, keep key considerations in mind, prepare yourself for changes to come, why there were some anomalies in the 2021 survey data, and what your company’s key communication points should be. Learn more at CaptainIntegrity.com
The group practice definition under the Stark Law is the mother of all Stark Law definitions. In this episode, Captain Integrity Bob Wade shares the detailed definitions and subdefinitions of Group Practice under the Stark Law. Hear how to understand each subdefinition, how members of a group practice differ from physicians, what happens if you don’t meet all definitions, surrogate methods, and how much payouts for settlements can be. Learn more at CaptainIntegrity.com
2020 and 2021 will have a long-term impact on Stark Law Compliance. In this episode, Captain Integrity Bob Wade details how the massive changes of the past couple years impact Fair Market Value and Stark Law Compliance. Hear the double whammy on physician compensation caused by COVID and the Physician Fee Schedule, why you need to be very careful in looking at total compensation, how to bill appropriately, insights from top surveys, and where there have been cash increases. Learn more at CaptainIntegrity.com
There are many lessons to learn from the 2021 False Claims Act settlements. In this episode, Captain Integrity Bob Wade recaps the major settlements under the False Claims Act in 2021 and what actionable insights we can pull from them. Hear why the qui tam weapon is still a large tool for the Department of Justice, healthcare is the largest source of false claims recovery for the government, personal liability continues to rise under the False Claims Act, how much was recovered in 2021, and the most game-changing settlements. Learn more at CaptainIntegrity.com
Value equals Benefit divided by Risk. In this episode, Captain Integrity Bob Wade welcomes Coker Group SVP Richard Romero to discuss the ins and outs of business valuations. Hear the 4 universal laws of valuation, how to make sure the standard of value applies to your situation, understand capacity constraints of your people and assets, when valuations come into play, and Richard’s favorite Fair Market Value definition. Learn more at CaptainIntegrity.com
How does the Stark Law sausage get made? In this episode, Captain Integrity Bob Wade welcomes Parkview Health Associate General Counsel Alex Krouse to break down his experience and advice for Stark Law compliance. Hear how to develop teams and processes for provider compensation, consider several factors as you shape your organization, lean on the structure you set up, what the data tells you, and why a larger team is helpful. Learn more at CaptainIntegrity.com
As a Board member, you need to have effective oversight of the fraud and abuse statutes. In this episode, Captain Integrity Bob Wade continues the discussion on what you need to know as a Board member for Stark Law compliance. Hear the the 5 main statutes of fraud and abuse, how to ensure your organization has a regimented process to validate compliance, why you need to be comfortable with the high-risk arrangements being made, which statute is “The Granddaddy of Them All,” and a recap of the 7 components of an effective compliance program (and the unwritten 8th). Learn more at CaptainIntegrity.com and email Bob for his Board dashboard report tool
The buck stops with the Board for Stark Law compliance. In this episode, Captain Integrity Bob Wade breaks down what you need to know as a Board member when it comes to Stark Law compliance. Hear the 7 components of an effective compliance program (and the unwritten 8th) you should receive info on, what Stark Law compliance training looks like, how to assess the operations of your Compliance Program, how long you can expect a resolution to take, and how much the fines and penalties can be. Learn more at CaptainIntegrity.com and email Bob for his Board dashboard report tool
Stark Law compliance requires a focus on emerging trends. In this episode, Captain Integrity Bob Wade takes you through more of the top emerging trends surrounding the Stark Law. Hear why commercial reasonableness is a qualitative analysis, you need to focus on the work performed, loss arrangements need to be analyzed and documented, quality and value compensation needs to be carefully monitored, and an example that takes you from Chicago to Cancún. Learn more at CaptainIntegrity.com and email Bob for his slides and checklist
Stark Law compliance requires a focus on emerging trends. In this episode, Captain Integrity Bob Wade takes you through some of the top emerging trends surrounding the Stark Law. Hear why effective compliance includes documentation and monitoring, Fair Market Value requires a review of all pertinent factors, you need documentation to rationalize exceeding the 90th percentile, how often to audit, and what type of compensation is king. Learn more at CaptainIntegrity.com and email Bob for his slides and checklist
Time share leasing is a common practice in healthcare but has numerous legal and compliance risks. In this episode, Captain Integrity Bob Wade continues the Stark Law real estate discussion by diving into the world of time share leasing. Hear how to factor in all services your hospital is going to provide, when the vacancy factor and administrative factor should be applied, how to monitor the arrangement, a few ways to structure arrangements, and a time share leasing math exercise. Learn more at CaptainIntegrity.com and email Bob for his real estate complexity checklist
Real estate is a major Stark Law and compliance issue. In this episode, Captain Integrity Bob Wade shares the vast real estate complexities that can arise under the Stark Law. Hear how often you should obtain a market survey, how to compare leases, what the lease arrangement must say, how to do a survey, and what Bob would do in a reality show with compliance officers. Learn more at CaptainIntegrity.com and email Bob for his real estate complexity checklist
A Fair Market Value Defensibility Analysis takes a compensation review one step further than a FMV Review under the Stark Law. In this episode, Captain Integrity Bob Wade points out the key differences between the two. Hear why there is a legal difference between a simple FMV review and a FMV Defensibility Analysis, whether commercial reasonableness is in play, how much to consider the subjective and business judgment factors, whether you can ask the government to give you an answer, and the FMV range. Learn more at CaptainIntegrity.com and email Bob for his checklist
Stark Law compliance begins with having the right people at the table motivated for the right business or medical need. In this episode, Captain Integrity Bob Wade breaks down 3 scenarios involving C-suite players and the Stark Law. Hear why legal and compliance teams should be part of the deal-making process, legal counsel should not just “paper” the deal, how to carefully consider what is motivating the deal, whether the services performed matter, and how to handle independent contractors. Learn more at CaptainIntegrity.com
If you think you have a Stark Law violation, take a step back, a deep breath, and follow Captain Integrity’s advice. In this episode, Captain Integrity Bob Wade shares what to do if you think your organization has a Stark Law violation. Hear what to do first, how to carefully consider all exceptions, consider all potential compliant resolutions, the 3 components for Stark Law to be implicated, and 3 excepted specialties. Learn more at CaptainIntegrity.com and email Bob for his 2 CliffsNotes slides
Physician Employment is a great integration strategy, but legal and compliance risks need to be managed. In this episode, Captain Integrity Bob Wade details the ins and outs of Physician Employment under Stark Law and shares real-life examples. Hear why there’s more flexibility compared to other aspects of the Stark Law, compensation must be based on personally performed services, you need to keep the focus on total cash compensation, when things could get problematic, and why it can be a very good tool. Learn more at CaptainIntegrity.com
The non-monetary compensation exception is so broad and complicated, it deserves a second episode. In this episode, Captain Integrity Bob Wade shares more real-life examples of the non-monetary compensation exception. Hear why you need to track non-monetary compensation, it helps to allocate a dollar amount for marketing trinkets, business dinners are considered to be compensation for the physician, examples from hospital holiday parties, and why the location of the meeting matters. Learn more at CaptainIntegrity.com
The dreaded non-monetary compensation exception can get pretty tricky. In this episode, Captain Integrity Bob Wade discusses what items meet the non-monetary compensation exception under the Stark Law, including real-life examples. Hear why the definition of remuneration plays a key part, it’s essential to track non-monetary compensation on an annual basis, how to track the value of a unified gift, the “cousin” exception, and the most common examples during the holiday season. Learn more at CaptainIntegrity.com
Hear Captain Integrity Bob Wade read his original Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Share the poem with your team and learn more at CaptainIntegrity.com
It’s important to understand the differences between ownership and compensation arrangements - both direct and indirect. In this episode, Captain Integrity Bob Wade breaks down the differences between each under the Stark Law, and where various exceptions apply. Hear how to draw out the various arrangements to determine what’s what, look at downward ownership in the chain, the definition of compensation, the Stand in the Shoes concept, and the impact of stock ownership under the Stark Law. Learn more at CaptainIntegrity.com
It’s important to make compliance relevant, focused on ethical behavior, and fun. In this special holiday episode, Captain Integrity Bob Wade reveals how he got into Stark Law compliance in the first place and reads a custom Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Hear what Bob represents clients on, how to make compliance fun, celebrate the people you work with, how Bob created Captain Integrity, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com
If a financial arrangement is unusual, it may not be commercially reasonable. In this episode, Captain Integrity Bob Wade details the key aspects of the commercial reasonableness standard and shares examples from real cases. Hear why commercial reasonableness is a qualitative analysis, how to think through if the financial arrangement makes sense, why it may not be commercially reasonable if the business risk shifts away from the physicians, how commercial reasonableness compares to Fair Market Value, and how it differs between organizations. Learn more at CaptainIntegrity.com
Value-based arrangements offer Fair Market Value freedom, but several challenges exist. In this episode, Captain Integrity Bob Wade details what value-based arrangements are and what they mean for your Stark Law cases. Hear why traditional Fair Market Value terms do not apply to value-based arrangements, continuous oversight and documentation is needed, what to do if you fail to meet the exception requirements, the difference between value and volume-based arrangements, and when your internal audit needs to get involved. Learn more at CaptainIntegrity.com
Stark Law violations can lead to some incredibly serious settlements. In this episode, Captain Integrity Bob Wade shares recent Stark Law cases with severe payouts. Hear why million-dollar settlements have occurred, how to document the services being performed, the areas you can’t tie compensation to, the top non-structural Fair Market Value issues, and what Bob needs to say with “air quotes.” Learn more at CaptainIntegrity.com
Where do you start when documenting Fair Market Value under the Stark Law? In this episode, Captain Integrity Bob Wade details everything from the starting point to key considerations. Hear why benchmark data makes a practical starting point, how to see if there’s alignment between productivity and total cash compensation, determine if there are subjective factors to support the total compensation, the 10 Percent Rule, and Hail Mary Defense. Learn more at CaptainIntegrity.com
Fair Market Value is a pinnacle issue when it comes to the Stark Law. In this episode, Captain Integrity Bob Wade explains the why, what, how, and beyond for Fair Market Value. Hear why Fair Market Value is a pinnacle issue, what methodology you can use to document Fair Market Value, what judgment factors to apply, the impacts on the lessor and lessee, and what caused a client to look like a deer in headlights. Learn more at CaptainIntegrity.com
Violations of the Stark Law can lead to some pretty serious damages, fines, and penalties. In this episode, Captain Integrity Bob Wade takes you through each with real-life examples. Hear why Stark Law damages can get so high, you should never create a circumvention scheme, what to do if you discover a Stark Law violation, the impact of the False Claims Act, and what Work RVUs are. Learn more at CaptainIntegrity.com
What are the definitions under the Stark Law? In this episode, Captain Integrity Bob Wade takes you through The Big 5 Definitions under the Stark law and more. Hear why the Stark Law is so definitionally driven, how to know when the Stark Law applies, why it’s important to know the definitions, rare exceptions to the definitions, and specific examples. Learn more at CaptainIntegrity.com
Does your healthcare organization have an effective compliance program? Captain Integrity is here to save the day. Welcome to Stark Integrity: The Stark Law and Compliance Podcast. In this pilot episode, you’ll meet host Bob Wade (aka Captain Integrity) and learn what the Stark Law is, the history of the Stark Law, and when it applies. As with every episode, you’ll come away with the 3 Captain Integrity Punch Points. Learn more at CaptainIntegrity.com