Stark Integrity

Latest Episodes:

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

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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

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Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” 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

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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

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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

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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

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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

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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

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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

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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

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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

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