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Stark Integrity — Government
Stark Integrity

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

Copyright: © 2024 Captain Integrity

Latest Episodes:

DOJ 6-Month Settlements (2024): The Issues, the Relators, and the Amounts Nov 19, 2024

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

Data Analytics & the False Claims Act: A Discussion with Mandy Asgeirsson, Director at BRG Nov 12, 2024

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

Physician Space Sharing & Stark Law Compliance: A Discussion with Mike Vetter, Partner at HMS Valuation Partners Nov 05, 2024

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

Quality Physician Compensation: A Discussion with Luis Argueso, Partner at InHealth Advisors Oct 29, 2024

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

Restoring Our Sanity Online: A Discussion with Author Mark Weinstein Oct 22, 2024

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

The Addams Family, 1960s, OIG Agents, Medicare, and Halloween Oct 15, 2024

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

Overpayment Notices, Mistakes, and Appeal Process: A Conversation with Knicole Emanuel, Partner at Nelson Mullins Oct 08, 2024

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

Free Lunches and Technology to Patients: What Is Permissible under CMP, AKS, and the Stark Law Sep 24, 2024

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

Part 2: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom Weiner Sep 17, 2024

“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

Part 1: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom Weiner Sep 10, 2024

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

Back to the Future with Chevron Deference: A Discussion with Phillip Mullinnix, Partner at Nelson Mullins Aug 28, 2024

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

Algorithmic Pricing, a New Compliance Risk: A Discussion with Bart Daniel, Partner at Nelson Mullins Aug 20, 2024

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

Mission Improbable: A Discussion with Kay Hashagen, Senior Consultant with LW Consulting, about the Impossible Day Aug 13, 2024

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

Open Payments: A Conversation with Aaron Narva, CEO of Conflixis, Regarding Compliance Findings and Nature of Reported Payments Aug 06, 2024

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

Designated Health Services (DHS): The Key to the Stark Law City Jul 23, 2024

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

Corporate Integrity Agreements (CIAs) and Independent Review Organizations (IROs): A Discussion with Harriett Wall, CEO of LW Consulting, Inc. Jul 16, 2024

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

Criminal National Health Care Fraud Enforcement Action 2024: A Discussion with Jillian Willis, Partner, Nelson Mullins Jul 09, 2024

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

Documenting Monitoring Efforts: A Discussion with James Rose from SunHawk Consulting Jul 02, 2024

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

Next Generation Root Cause Analysis: A Discussion with James Rose from SunHawk Consulting Jun 25, 2024

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

Correlation Theory vs. Volume or Value Varying Standard vs. Volume or Value Determination Standard Jun 18, 2024

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

A Rare Bird: Fair Market Value for Key Opinion Leaders Jun 11, 2024

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

Percentage Arrangements under the Stark Law Jun 05, 2024

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 May 22, 2024

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

Compensation Learnings from AAPCP Annual Conference: Discussion with Chris Fete, Partner, Pinnacle Healthcare Consulting May 14, 2024

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 to Identify Covert Retaliation May 01, 2024

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

Marketing under the Stark Law and Anti-Kickback Statute (AKS) Apr 24, 2024

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 Exception? Apr 16, 2024

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

Are wRVUs Physician Compensation's Holy Grail? Apr 10, 2024

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

Volume or Value Conundrum Apr 02, 2024

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

Part 2: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions Mar 27, 2024

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

Part 1: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions Mar 20, 2024

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

Importance of Documentation in Physician Financial Arrangements Mar 12, 2024

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

DOJ 2023 Fiscal Year False Claims Act Settlements Mar 05, 2024

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

The Connection (and Disconnect) between Commercial Reasonableness and Fair Market Value Feb 28, 2024

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

Stark Law and Substance Abuse and Addiction Feb 20, 2024

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

Fair Market Value under New Stark Law Regulations: A Discussion with Tim Smith from TS Healthcare Consulting Feb 14, 2024

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

Employing Hospital-Based Specialists…Now What? A Discussion with Joe Aguilar and Natalie Bell from HMS Valuation Partners Feb 06, 2024

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

Part 3: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP Jan 31, 2024

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

Part 2: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP Jan 23, 2024

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

Part 1: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP Jan 17, 2024

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

Crisis Communication Management in Healthcare: A Discussion with Eileen Wixted from Wixted & Co. Jan 10, 2024

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

Part 2: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower Jan 03, 2024

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

Part 1: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower Dec 26, 2023

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

Part 2: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health Dec 19, 2023

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

Part 1: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health Dec 13, 2023

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

Stark Law Holiday Poems: “'Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” and “Jolly OIG Agent” Dec 10, 2023

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

Jolly OIG Agent: 2023 Stark Integrity Holiday Poem Dec 06, 2023

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

Fixed Asset Valuations: A Discussion with Mike Vetter with HMS Valuation Partners Nov 29, 2023

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

Recruitment and Physician Needs Assessment (PNA): A Discussion with Stephen Ross and Justin Chamblee from Coker Group Nov 22, 2023

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

Medical Directors: Can't Live With Them, Can't Live Without Them Nov 14, 2023

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

Stark Law Timing: 1 Year, 2 Years, 5 Years, and More Timing Limitations Nov 07, 2023

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

Hospital-Based Financial Arrangements: A Discussion with Joe Aguilar with HMS Valuation Partners Nov 01, 2023

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

Master List Requirement under the Stark Law Explained Oct 24, 2023

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

Stark Law Settlements under the Self-Referral Disclosure Protocol (SRDP): How Long and How Much? Oct 18, 2023

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

Stark Law Compliance Mash Oct 11, 2023

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

History of Fair Market Value and Wade's Personal Impact on FMV Standard Oct 04, 2023

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

Academic Medical Centers Exception: What Is It and How Can It Be Used? Sep 26, 2023

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

Operational Challenges in Physician Financial Arrangements: Who Is Driving the Bus? Sep 19, 2023

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

False Claims Act 2023 Mid-Year Review Sep 12, 2023

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

CARES Act Fraud: Discussion with Bart Daniel from Nelson Mullins Aug 29, 2023

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 in the Healthcare Industry: Discussion with Ashley Graver from Coker Group Aug 15, 2023

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 in the Healthcare Industry: Discussion with Bart Daniel from Nelson Mullins Aug 01, 2023

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

Fair Market Value Analysis Mistakes Jul 25, 2023

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

Time-Share Lease Arrangements in Healthcare: Conversation with Ron Young from The Advisory Group Jul 18, 2023

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

Fair Market Value, Commercial Reasonableness, and Remuneration: Does FMV Cover All Sins? Jul 11, 2023

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

False Claims Act: Supreme Court Holds Knowledge Is Subjective Not Objective: Discussion with Bart Daniel from Nelson Mullins Jun 13, 2023

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

Part 2: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting Jun 06, 2023

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

Part 1: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting May 30, 2023

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

False Claims Act (FCA): Is Knowledge Objective or Subjective May 24, 2023

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

Advanced Practice Providers (APPs): Compliance Risks and Safeguards May 16, 2023

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

Eliminating Kickbacks in Recovery Act (EKRA): Comparison with the AKS May 02, 2023

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

Part 2: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel Apr 25, 2023

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

Part 1: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel Apr 18, 2023

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

Stark Law and Anti-Kickback Issues with Healthcare Transactions Apr 11, 2023

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

Unique Trends and Compliance Issues with Value-Based Reimbursement Arrangements: A Discussion with Christine Worthen of Nelson Mullins Mar 21, 2023

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

Logos and Slogans to Promote an Effective Compliance Program Mar 14, 2023

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

One Purpose Test: Greber vs. Holland; A discussion with Gabe Imperato with Nelson Mullins Mar 08, 2023

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: Legal or Illegal? Feb 28, 2023

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

DOJ 2022 False Claims Act Settlements and Judgments: Learning Points Feb 22, 2023

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

Compliance Effectiveness: It Is about the Culture of the Organization Feb 14, 2023

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

Value-Based Arrangements Key Issues: A Discussion with Kelly Conroy from Pinnacle Healthcare and Ed White from Nelson Mullins Feb 08, 2023

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

Medical Necessity: A Major Compliance Issue and Risk Jan 24, 2023

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

Audit Work Plan Development: The Who, What, and How Jan 17, 2023

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

Corporate Practice of Medicine (CPOM) Compliance: A Discussion with Heather Miller from Nelson Mullins Jan 10, 2023

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

Stark Law Holiday Poems: “'Twas the Night before the Subpoena” and "Rudy the Seasoned Compliance Officer” Dec 07, 2022

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

Captain Integrity Holiday Message, including "Rudy the Seasoned Compliance Officer” Nov 29, 2022

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

Compliance Program Development and Effectiveness: A Discussion with Chief Compliance Officer Steve Sugrue with DocGo Nov 22, 2022

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

Creating Value through Compliance: A Conversation with Jerry Shafran, CEO of YouCompli Nov 15, 2022

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

6 Deadly Mistakes in Value-Based Activities Compensation under Stark and AKS Nov 08, 2022

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

What? The Stark Law Covers Physicians' Charitable Contributions of Money and Services? Oct 25, 2022

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 Organization (IRO) Services Under (or Outside) a Corporate Integrity Agreement Oct 18, 2022

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

Part 2: Children's Hospitals, Medicaid, and Stark Law Compliance: A Discussion with Andy Lenobel with Nationwide Children's Hospital Oct 11, 2022

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

Part 1: Children's Hospitals, Medicaid, and Stark Law Compliance Oct 05, 2022

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

Part 2: Examples of Interplay between Peer Review and Compliance, False Claims Act, and Stark Law Sep 27, 2022

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

Part 1: Interplay between Peer Review and Compliance, False Claims Act, and Stark Law Sep 20, 2022

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

Rare Qui Tam Jury False Claims Act Case: Learning Points Regarding FCA Cases Including Eli Lilly/Astellas Pharma Verdict Sep 14, 2022

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

False Claims Act Settlement Updates - Midyear 2022: The Dollars and the Issues Sep 06, 2022

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

Legal and Operational Issues with Accountable Care Organizations/Value Based Arrangements: A Discussion with Kelly Conroy with Pinnacle Healthcare Consulting Aug 31, 2022

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 to Respond to a Civil Investigative Demand (CID) Issued by the Department of Justice (DOJ) Aug 23, 2022

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

Office of Inspector General (OIG) Self-Disclosure Protocol: Different from the CMS SRDP Aug 16, 2022

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

How to Use the Self-Referral Disclosure Protocol (SRDP) to Voluntarily Report Stark Law Violations Aug 10, 2022

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): Fraud Issues and OIG Advisory Opinion 22-14 Aug 03, 2022

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: What Are They and Why Are They Engaged? Jul 26, 2022

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

Selecting a Compliance Officer: Why, What, Who? Jul 20, 2022

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

Tick-Tock: Time Reports and Stark Law Compliance Jul 12, 2022

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: Stark Law Lifeguard Training Jul 05, 2022

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. the Stark Law Jun 28, 2022

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

Shared Services Performed by Physicians and APPs: A Discussion with Amy Noecker and Zachary Hartsell from SullivanCotter Jun 21, 2022

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

Physician Liability and Qui Tam Cases under the Stark Law and AKS: A Discussion with Marlan Wilbanks, Esq. Jun 14, 2022

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

Physician Work Effort Tracking under the Stark Law: A Discussion with Gail Peace with Ludi, Inc. Jun 07, 2022

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

Intent under the Stark Law: "But I Thought Stark Was Civil, Not Criminal" May 31, 2022

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

Non-Physician Practitioner Recruitment under the Stark Law: Proceed with Caution May 24, 2022

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

Current Physician Compensation Trends from the AAPCP Conference: A Discussion with Anthony Domanico from VMG Health May 17, 2022

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

Part 2 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational Challenges May 10, 2022

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

Part 1 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational Challenges May 03, 2022

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

Life and Learnings from a CIA: A Discussion with Lucia Pizano-Urbina from Broward Health Apr 26, 2022

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

Group Practice Part 2: Stark Law's In-Office Ancillary Services Exception Apr 19, 2022

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

2021 CMS-Revised wRVUs and Impact on Physician Compensation: A Discussion with Bob Madden of SullivanCotter Apr 12, 2022

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

Group Practices Part 1: The Mother of All Stark Law Definitions Apr 05, 2022

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

Impact of COVID, 2021 wRVU Values, and 2022 Physician Fee Schedule on Fair Market Value and Stark Law Compliance Mar 29, 2022

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

2021 Settlements Under the False Claims Act, Stark Law, and Anti-Kickback Statute - Lessons Learned Mar 23, 2022

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

Business Valuations under AKS and Stark Law with Richard Romero from Coker Group Mar 16, 2022

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

Stark Law, Fair Market Value, and Approval Process Discussion with Parkview Health Attorney Alex Krouse Mar 08, 2022

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

Board Members Part 2: Compliance and Key Legal Requirements Including the Stark Law Mar 01, 2022

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

Board Members Part 1: Compliance and Key Legal Requirements Including the Stark Law Feb 22, 2022

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 Emerging Trends: Commercial Reasonableness, Directed Referrals, NPP Supervision, Call, Quality, and Loss Arrangements Feb 15, 2022

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 Emerging Trends: Approval Process, FMV, 90th Percentile Compensation, and Independent Contractors Feb 09, 2022

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

Real Estate II: Time Share Leasing Arrangements Under the Stark Law Feb 01, 2022

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 Compliance Under the Stark Law Jan 25, 2022

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

Why is a Fair Market Value Defensibility Analysis Different from a FMV Review under the Stark Law? Jan 18, 2022

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

Let's Make a Deal: Stark Law Compliance in the C-Suite Jan 12, 2022

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

Stark Violations: Possible Stark Law Remedies Jan 05, 2022

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 Agreements Under Stark Law Dec 28, 2021

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

More Examples of Stark Law's Non-Monetary Compensation Exception Dec 20, 2021

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

Stark Law's Non-Monetary Compensation Exception With Real Examples Dec 15, 2021

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

Stark Law Holiday Poem: 'Twas The Night Before The Subpoena Dec 10, 2021

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

Applying the Stark Law to Ownership and Compensation Arrangements - Direct and Indirect Dec 07, 2021

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

Stark Law: 'Twas The Night Before The Subpoena Nov 30, 2021

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

Stark Law’s Commercial Reasonableness Standard Nov 23, 2021

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: The Stark Law/AKS Requirements Nov 16, 2021

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

What Are Some Examples of Fair Market Value Liability Under the Stark Law? Nov 09, 2021

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

What Is the Practical Application of Fair Market Value Under the Stark Law? Nov 03, 2021

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

Why Is Fair Market Value the Pinnacle Stark Law Issue? Oct 26, 2021

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

What Are the Damages, Fines, and Penalties Under the Stark Law? Oct 19, 2021

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 Stark Law Definitions? Oct 13, 2021

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

Welcome to Stark Integrity: What Is the Stark Law? Oct 05, 2021

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

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