Stark Integrity

Latest Episodes:

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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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