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


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