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    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

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    Copyright: © 2026 Captain Integrity

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

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