Shows
Stark IntegrityPart 3: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren SkylesSend us a textActively 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
2026-01-2817 minStark IntegrityPart 2: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren SkylesSend us a textBeing 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
2026-01-2119 minStark IntegrityPart 1: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren SkylesSend us a textHealthcare 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
2026-01-1422 minStark IntegrityCompliance Program Effectiveness: The 8th Element of an Effective Compliance ProgramSend us a textEvaluating 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
2026-01-0721 minStark Integrity2025 Christmas Episode with “Santa Baby” ParodySend us a textIt’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
2025-12-1022 minStark Integrity“Personally Performed” Services and Autonomous VehiclesSend us a textCould “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
2025-11-1221 minStark IntegrityCaptain Integrity and the Curse of Stark Hallow and Halloween Costumes through the YearsSend us a textBoo! 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
2025-10-2219 minStark IntegrityOne Big Beautiful Bill’s Impact on HealthcareSend us a textWondering 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
2025-06-0421 minStark IntegrityPart 1: Ambulatory Surgery Centers (ASCs): The Nuts and Bolts and Legal RequirementsSend us a textIn 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
2025-03-1221 minStark IntegrityPart 1: Why Is Sanitizing wRVUs Important (Comp RVU) vs. Reported wRVUs: A Discussion with Matt BonDurant, SVP at ProCARESend us a textThere’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
2025-02-1920 minStark IntegrityPooled Compensation: Creation, Distribution, and the Probability Factor for Personally Performed ServicesSend us a textPooled 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
2025-02-0521 minStark Integrity2024 “Winners” for Most Egregious US Healthcare ProfiteeringSend us a textDrumroll, 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
2025-01-1520 minStark IntegrityThe 12 Days of Compliance: 2024 Holiday SpecialSend us a textWant 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
2024-12-0421 minStark IntegrityQuality Physician Compensation: A Discussion with Luis Argueso, Partner at InHealth AdvisorsSend us a textQuality 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
2024-10-3026 minStark IntegrityThe Addams Family, 1960s, OIG Agents, Medicare, and HalloweenSend us a textWhat 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...
2024-10-1619 minStark IntegrityPart 2: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom WeinerSend us a text“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
2024-09-1829 minStark IntegrityPart 1: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom WeinerSend us a textAnd 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 mo...
2024-09-1123 minStark IntegrityDesignated Health Services (DHS): The Key to the Stark Law CitySend us a textA 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...
2024-07-2422 minStark IntegrityThe Connection (and Disconnect) between Commercial Reasonableness and Fair Market ValueSend us a textFair 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
2024-02-2822 minStark IntegrityPart 3: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCPSend us a textLook 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 fu...
2024-01-3132 minStark IntegrityPart 2: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCPSend us a textYou 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, ho...
2024-01-2431 minStark IntegrityPart 1: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCPSend us a textA 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 Va...
2024-01-1727 minStark IntegrityPart 2: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview HealthSend us a textBe 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...
2023-12-2030 minStark IntegrityPart 1: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview HealthSend us a textMitigate 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 Bo...
2023-12-1326 minStark IntegrityJolly OIG Agent: 2023 Stark Integrity Holiday PoemSend us a textThank 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
2023-12-0613 minStark IntegrityHistory of Fair Market Value and Wade's Personal Impact on FMV StandardSend us a textLet’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
2023-10-0425 minStark IntegrityAdvanced Practice Providers (APPs): Compliance Risks and SafeguardsSend us a textIncorporating 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
2023-05-1721 minStark IntegrityStark Law and Anti-Kickback Issues with Healthcare TransactionsSend us a textHealthcare 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
2023-04-1218 minStark IntegrityUnique Trends and Compliance Issues with Value-Based Reimbursement Arrangements: A Discussion with Christine Worthen of Nelson MullinsSend us a textThere’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
2023-03-2218 minStark IntegrityLogos and Slogans to Promote an Effective Compliance ProgramSend us a textCreating 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
2023-03-1519 minStark IntegrityOne Purpose Test: Greber vs. Holland; A discussion with Gabe Imperato with Nelson MullinsSend us a textUnfortunate 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...
2023-03-0825 minStark IntegrityWaiving Copays: Legal or Illegal?Send us a textWaiving 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
2023-03-0121 minStark IntegrityDOJ 2022 False Claims Act Settlements and Judgments: Learning PointsSend us a textThere’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
2023-02-2223 minStark IntegrityCompliance Effectiveness: It Is about the Culture of the OrganizationSend us a textOne 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
2023-02-1519 minStark IntegrityValue-Based Arrangements Key Issues: A Discussion with Kelly Conroy from Pinnacle Healthcare and Ed White from Nelson MullinsSend us a textThe 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 a...
2023-02-0830 minStark IntegrityMedical Necessity: A Major Compliance Issue and RiskSend us a textPhysicians 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
2023-01-2520 minStark IntegrityAudit Work Plan Development: The Who, What, and HowSend us a textHow 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
2023-01-1823 minStark IntegrityCorporate Practice of Medicine (CPOM) Compliance: A Discussion with Heather Miller from Nelson MullinsSend us a textMake 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
2023-01-1124 minStark IntegrityStark Law Holiday Poems: “'Twas the Night before the Subpoena” and "Rudy the Seasoned Compliance Officer”Send us a textHear 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
2022-12-0709 minStark IntegrityCaptain Integrity Holiday Message, including "Rudy the Seasoned Compliance Officer”Send us a textThis 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 shar...
2022-11-3019 minStark IntegrityCompliance Program Development and Effectiveness: A Discussion with Chief Compliance Officer Steve Sugrue with DocGoSend us a textBe 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
2022-11-2321 minStark IntegrityCreating Value through Compliance: A Conversation with Jerry Shafran, CEO of YouCompliSend us a textUse 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
2022-11-1618 minStark Integrity6 Deadly Mistakes in Value-Based Activities Compensation under Stark and AKSSend us a textCan 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
2022-11-0921 minStark IntegrityWhat? The Stark Law Covers Physicians' Charitable Contributions of Money and Services?Send us a textBelieve 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
2022-10-2622 minStark IntegrityLegal Independent Review Organization (IRO) Services Under (or Outside) a Corporate Integrity AgreementSend us a textLegal 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...
2022-10-1922 minStark IntegrityPart 2: Children's Hospitals, Medicaid, and Stark Law Compliance: A Discussion with Andy Lenobel with Nationwide Children's HospitalSend us a textThorough 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
2022-10-1229 minStark IntegrityPart 1: Children's Hospitals, Medicaid, and Stark Law ComplianceSend us a textDoes 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) h...
2022-10-0621 minStark IntegrityPart 2: Examples of Interplay between Peer Review and Compliance, False Claims Act, and Stark LawSend us a textDetermining 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 ph...
2022-09-2822 minStark IntegrityPart 1: Interplay between Peer Review and Compliance, False Claims Act, and Stark LawSend us a textPhysician 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
2022-09-2122 minStark IntegrityRare Qui Tam Jury False Claims Act Case: Learning Points Regarding FCA Cases Including Eli Lilly/Astellas Pharma VerdictSend us a textJury 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
2022-09-1421 minStark IntegrityFalse Claims Act Settlement Updates - Midyear 2022: The Dollars and the IssuesSend us a textThe 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
2022-09-0722 minStark IntegrityLegal and Operational Issues with Accountable Care Organizations/Value Based Arrangements: A Discussion with Kelly Conroy with Pinnacle Healthcare ConsultingSend us a textAccountable 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
2022-08-3120 minStark IntegrityHow to Respond to a Civil Investigative Demand (CID) Issued by the Department of Justice (DOJ)Send us a textHow 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
2022-08-2421 minStark IntegrityOffice of Inspector General (OIG) Self-Disclosure Protocol: Different from the CMS SRDPSend us a textThe 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 Capt...
2022-08-1725 minStark IntegrityHow to Use the Self-Referral Disclosure Protocol (SRDP) to Voluntarily Report Stark Law ViolationsSend us a textIf 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 po...
2022-08-1027 minStark IntegrityContinuing Medical Education (CME): Fraud Issues and OIG Advisory Opinion 22-14Send us a textContinuing 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...
2022-08-0324 minStark IntegrityCompliance Experts and Monitors: What Are They and Why Are They Engaged?Send us a textCompliance 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
2022-07-2723 minStark IntegritySelecting a Compliance Officer: Why, What, Who?Send us a textBeing 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
2022-07-2021 minStark IntegrityTick-Tock: Time Reports and Stark Law ComplianceSend us a textTime 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
2022-07-1325 minStark IntegrityCompensation Pools: Stark Law Lifeguard TrainingSend us a textCompensation 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
2022-07-0624 minStark IntegrityK.I.S.S. the Stark LawSend us a textK.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
2022-06-2921 minStark IntegrityShared Services Performed by Physicians and APPs: A Discussion with Amy Noecker and Zachary Hartsell from SullivanCotterSend us a textProviders 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
2022-06-2230 minStark IntegrityPhysician Liability and Qui Tam Cases under the Stark Law and AKS: A Discussion with Marlan Wilbanks, Esq.Send us a textIt 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 qu...
2022-06-1529 minStark IntegrityPhysician Work Effort Tracking under the Stark Law: A Discussion with Gail Peace with Ludi, Inc.Send us a textIt’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
2022-06-0825 minStark IntegrityIntent under the Stark Law: "But I Thought Stark Was Civil, Not Criminal"Send us a textThe 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-K...
2022-06-0121 minStark IntegrityNon-Physician Practitioner Recruitment under the Stark Law: Proceed with CautionSend us a textHospitals 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
2022-05-2522 minStark IntegrityCurrent Physician Compensation Trends from the AAPCP Conference: A Discussion with Anthony Domanico from VMG HealthSend us a textWe 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...
2022-05-1826 minStark IntegrityPart 2 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational ChallengesSend us a textUnder 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
2022-05-1127 minStark IntegrityPart 1 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational ChallengesSend us a textUnder 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
2022-05-0424 minStark IntegrityLife and Learnings from a CIA: A Discussion with Lucia Pizano-Urbina from Broward HealthSend us a textHow 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
2022-04-2727 minStark IntegrityGroup Practice Part 2: Stark Law's In-Office Ancillary Services ExceptionSend us a textIf 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
2022-04-2025 minStark Integrity2021 CMS-Revised wRVUs and Impact on Physician Compensation: A Discussion with Bob Madden of SullivanCotterSend us a textPhysician 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
2022-04-1327 minStark IntegrityGroup Practices Part 1: The Mother of All Stark Law DefinitionsSend us a textThe 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
2022-04-0622 minStark IntegrityImpact of COVID, 2021 wRVU Values, and 2022 Physician Fee Schedule on Fair Market Value and Stark Law ComplianceSend us a text2020 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
2022-03-3022 minStark Integrity2021 Settlements Under the False Claims Act, Stark Law, and Anti-Kickback Statute - Lessons LearnedSend us a textThere 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
2022-03-2321 minStark IntegrityBusiness Valuations under AKS and Stark Law with Richard Romero from Coker GroupSend us a textValue 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
2022-03-1625 minStark IntegrityStark Law, Fair Market Value, and Approval Process Discussion with Parkview Health Attorney Alex KrouseSend us a textHow 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
2022-03-0929 minStark IntegrityBoard Members Part 2: Compliance and Key Legal Requirements Including the Stark LawSend us a textAs 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...
2022-03-0226 minStark IntegrityBoard Members Part 1: Compliance and Key Legal Requirements Including the Stark LawSend us a textThe 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...
2022-02-2324 minStark IntegrityStark Law Emerging Trends: Commercial Reasonableness, Directed Referrals, NPP Supervision, Call, Quality, and Loss ArrangementsSend us a textStark 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
2022-02-1624 minStark IntegrityStark Law Emerging Trends: Approval Process, FMV, 90th Percentile Compensation, and Independent ContractorsSend us a textStark 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
2022-02-0921 minStark IntegrityReal Estate II: Time Share Leasing Arrangements Under the Stark LawSend us a textTime 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...
2022-02-0225 minStark IntegrityReal Estate Compliance Under the Stark LawSend us a textReal 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
2022-01-2624 minStark IntegrityWhy is a Fair Market Value Defensibility Analysis Different from a FMV Review under the Stark Law?Send us a textA 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...
2022-01-1921 minStark IntegrityLet's Make a Deal: Stark Law Compliance in the C-SuiteSend us a textStark 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
2022-01-1220 minStark IntegrityStark Violations: Possible Stark Law RemediesSend us a textIf 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
2022-01-0525 minStark IntegrityPhysician Employment Agreements Under Stark LawSend us a textPhysician 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
2021-12-2923 minStark IntegrityMore Examples of Stark Law's Non-Monetary Compensation ExceptionSend us a textThe 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
2021-12-2023 minStark IntegrityStark Law's Non-Monetary Compensation Exception With Real ExamplesSend us a textThe 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
2021-12-1528 minStark IntegrityStark Law Holiday Poem: 'Twas The Night Before The SubpoenaSend us a textHear 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
2021-12-1003 minStark IntegrityApplying the Stark Law to Ownership and Compensation Arrangements - Direct and IndirectSend us a textIt’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
2021-12-0824 minStark IntegrityStark Law: 'Twas The Night Before The SubpoenaSend us a textIt’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
2021-12-0123 minStark IntegrityStark Law’s Commercial Reasonableness StandardSend us a textIf 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
2021-11-2422 minStark IntegrityValue-Based Arrangements: The Stark Law/AKS RequirementsSend us a textValue-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
2021-11-1725 minStark IntegrityWhat Are Some Examples of Fair Market Value Liability Under the Stark Law?Send us a textStark 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
2021-11-1021 minStark IntegrityWhat Is the Practical Application of Fair Market Value Under the Stark Law?Send us a textWhere 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
2021-11-0322 minStark IntegrityWhy Is Fair Market Value the Pinnacle Stark Law Issue?Send us a textFair 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
2021-10-2723 minStark IntegrityWhat Are the Damages, Fines, and Penalties Under the Stark Law?Send us a textViolations 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
2021-10-2021 minStark IntegrityWhat Are the Stark Law Definitions?Send us a textWhat 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
2021-10-1322 minStark IntegrityWelcome to Stark Integrity: What Is the Stark Law?Send us a textDoes 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
2021-10-0522 min