Stark Integrity

Send us Fan Mail This week’s Stark Integrity is a compilation of all the Christmas holiday specials from 2021-2025. Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” “Jolly OIG Agent,” “The 12 Days of Compliance,” and “Captain Integrity.” Share the poems with your team and learn more at CaptainI...

Send us Fan Mail It’s time for the 2025 Stark Integrity podcast Christmas Special! In this special holiday episode, Captain Integrity Bob Wade reflects on 2025 and sings his latest custom Stark Law holiday carol, a “Santa Baby” parody. Hear Bob’s professional highlights from the year, the latest with his grandkids & Disney World, his accident involving a ladder, the history of “Santa Baby,” an...

Send us Fan Mail Audit results could lead to False Claims Act liability (FCA). In this episode, Captain Integrity Bob Wade talks through audits and potential FCA liability under the Stark Law. Hear why you should do probe audits, when you need to take corrective action, how to avoid the draconian fines & penalties under the FCA, famous cases involving the FCA, and not-so-funny examples of thin...

Send us Fan Mail Some spouses may not know their financial arrangements may implicate the Stark Law. In this episode, Captain Integrity Bob Wade explains the marital considerations under the Stark Law. Hear when the Stark Law is implicated, why you need to train people who are approving payments to understand who owns the companies and their ties to physicians, how to exercise due diligence as it...

Send us Fan Mail You need to know what AI tools your organization is working with. In this episode, Captain Integrity Bob Wade dives into AI use (Artificial Intelligence) and guardrails in healthcare with Natalie Ramello, VP, Chief Compliance & Audit Officer, UT Southwestern Medical Center. Hear why integrity is the launchpad for innovation, how to protect the data, why AI requires accountabil...

Send us Fan Mail Could “personally performed” services be compared to a self-driving vehicle? In this episode, Captain Integrity Bob Wade talks the parallels under the Stark Law. Hear why “personally performed” is frequently quoted in the Stark Law and Stark Law exceptions, what deems a service to be a referral, why a referral would not meet the Stark Law exceptions, whether the situation gets tri...

Send us Fan Mail TPE (Targeted Probe and Educate) audits look benign, but could be scary. In this episode, Captain Integrity Bob Wade explores TPE audits with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to know if you’re an outlier, the importance of responding timely, why the best defense is a strong offense, how a TPE audit works, and a bunch of things that look benign - but cou...

Send us Fan Mail Interviews are key for risk assessment. In this episode, Captain Integrity Bob Wade dives into the value of compliance advisory support with Sheila Limmroth, Executive Consultant and Compliance Officer at Pinnacle Healthcare. Hear why advisory does not equal incompetence, how to grow from within, how to build a stronger compliance program, why no person or compliance program is pe...

Send us Fan Mail Boo! In this special Halloween episode, Captain Integrity Bob Wade shares his original poem “Captain Integrity and the Curse of Stark Hallow” and a trip down Halloween costume history. Hear the most popular Halloween costumes from 1950-2005, the top Halloween costume on your birth year, Bob’s all-time favorite Halloween costume, the common theme with Halloween costumes over the ye...

Send us Fan Mail  For every dollar of open payments money that goes into a hospital staff, there’s $7 of increase in spend on average to those firms. In this episode, Captain Integrity Bob Wade talks transparency & action as they relate to The 2025 Open Payments Report with Aaron Narva, CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts, how to know your healthcare...

Send us Fan Mail If you’re going to give a gift to one physician, give it to all your physicians. In this episode, Captain Integrity Bob Wade rebroadcasts Part 3 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear an insightful Q&A session on non-monetary compensation and medical staff incidental benefits, how to handle gift certificates under...

Send us Fan Mail Doctors believe the medical staff funds are owned by them. In this episode, Captain Integrity Bob Wade rebroadcasts Part 2 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the benefits you can provide, how to handle lunches for doctors, the difference between employed & independent physicians as it relates to the Stark Law,...

Send us Fan Mail There’s a lot to consider when it comes to the Stark Law. In this episode, Captain Integrity Bob Wade rebroadcasts Part 1 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the basics of the Stark Law, notable exceptions, whether you can accept gifts in the healthcare industry, what to do if you’ve made a mistake in Stark Law com...

Send us Fan Mail The False Claims Act (FCA) has 3 knowledge qualifiers. In this episode, Captain Integrity Bob Wade unpacks the difference between actual knowledge, deliberate ignorance, and reckless disregard as it relates to the Stark Law. Hear why the 3 knowledge qualifiers exist, how risk impacts the False Claims Act, why you have to look at the history with respect to reviews, examples of the...

Send us Fan Mail Performing billing and documentation audits & reviews are important for an effective compliance program. In this episode, Captain Integrity Bob Wade explains what a probe review is and when you need to keep digging for a statistically valid review. Hear how to design your probe review using the RAT-STATS program, when you can treat your probe review as an educational review, w...

Send us Fan Mail The misuse of Modifier 25 can result in overcompensation if the physician is being compensated through a wRVU productivity model. In this episode, Captain Integrity Bob Wade lays out the connection between Modifier 25 and wRVUs as they relate to the Stark Law. Hear what questions to ask when it comes to Modifier 25, how to document separateness & significance, the connection b...

Send us Fan Mail Don’t shoot the messenger. In this episode, Captain Integrity Bob Wade explores the nature of delivering bad news as a Compliance Officer & beyond. Hear how to deliver bad news, why you should soften the soil, how to use the sandwich approach when delivering bad news, the dangers of sugarcoating, and the history of the phrase Don’t Shoot the Messenger. Learn more at CaptainInt...

Send us Fan Mail Auditor: you are not a Compliance Officer. In this episode, Captain Integrity Bob Wade dives into the complementary roles of Compliance Officer and Auditor. Hear the difference between the two roles, what each position is responsible for, why the roles are separate & distinct, the history of the Charles Horton Cooley looking-glass self quote, and some notable Hamilton lyrics....

Send us Fan Mail Audit yourself. In this episode, Captain Integrity Bob Wade tackles the 2025 healthcare enforcement priorities with Brook Andrews, Partner at Nelson Mullins. Hear why healthcare enforcement is not going away, how the government’s healthcare enforcement tools will continue to get better, how to build a culture of transparency, who healthcare enforcement is targeting, and the parabl...

Send us Fan Mail If medical staff funds are in a hospital account, the Stark Law applies. In this episode, Captain Integrity Bob Wade details medical staff funds as they relate to the Stark Law. Hear when the Stark Law applies, why the medical staff funds are restricted, what to consider if the medical staff funds are not in a hospital account, the risks when it comes to medical staff funds, and ...

Send us Fan Mail If you’re paying your doctor for an hour of service, you better make sure your doctor is working an hour of service. In this episode, Captain Integrity Bob Wade breaks down what happens when financial arrangements exceed Fair Market Value (FMV). Hear why it’s important to keep tabs on your doctors, why monitoring is such a key component of compliance, what to do if financial arran...

Send us Fan Mail Healthcare providers should be concerned. In this episode, Captain Integrity Bob Wade explores the new DOJ and HHS False Claims Act Working Group targeting healthcare fraud with Knicole Emanuel, Partner at Nelson Mullins. Hear why you should review your compliance program, reassess your risk exposure, consider voluntary disclosure, the areas the working group is targeting, and why...

Send us Fan Mail The larger the country, the longer it takes to get trials approved. In this episode, Captain Integrity Bob Wade explores how compliance works for national & international clinical trials with Julio Martinez-Clark, CEO of bioaccess. Hear how clinical research is global, why some countries approve trials quicker, why patients in developing economies need to have access to these...

Send us Fan Mail The best defense is a good offense. In this episode, Captain Integrity Bob Wade discusses the dreaded UPICs (Unified Program Integrity Contractors) with Harriett Wall, President & CEO of LW Consulting. Hear why a UPIC audit is a very serious matter, why you need to organize your team as soon as possible, how to put together a robust compliance plan, who could be the subject of...

Send us Fan Mail Attackers only win when you have no choice left. In this episode, Captain Integrity Bob Wade breaks down the importance of cybersecurity in healthcare & compliance with Matthew Toussain, Founder of Open Security. Hear how to focus on the basics, why you shouldn’t trust anyone, how to know your risk and the enemy, how to stay ahead of cybersecurity attacks, and Matthew’s backgr...