Stark Integrity

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...

Send us Fan Mail AI in healthcare is moving at a pace we’ve never seen. In this episode, Captain Integrity Bob Wade explores the fascinating future of AI (Artificial Intelligence) in healthcare with David Norris, Co-Founder & CEO of Affineon Health. Hear why you should embrace AI as a healthcare provider, why this is the most transformative time for healthcare providers, how AI will significan...

Send us Fan Mail Compliance programs matter. In this episode, Captain Integrity Bob Wade discusses the DOJ Civil/Criminal Updated Enforcement Plan with Jillian Willis, Partner at Nelson Mullins. Hear how the DOJ (Department of Justice) is committed to investigating & prosecuting white-collar crime, how the Corporate Whistleblower Awards Pilot Program incentivizes whistleblowers, why compliance...

Send us Fan Mail Wondering how the One Big Beautiful Bill will impact healthcare if it passes the Senate? In this episode, Captain Integrity Bob Wade shares all you need to know. Hear how a substantial number of Medicaid beneficiaries would lose their status, how rural hospitals could reopen, why the annual increases in the Medicare conversion factor will decrease, the most important takeaways Bob...

Send us Fan Mail Are there ethical considerations in physician compensation arrangements? In this episode, Captain Integrity Bob Wade explains why the answer is a resounding YES. Hear the difference between ethics, compliance, and integrity, why physician compensation models could cause physicians to conduct themselves in an unethical manner, the value society has placed on different occupations,...

Send us Fan Mail Is timely and accurate completion of medical records all about the money? In this episode, Captain Integrity Bob Wade explains why there’s a whole lot more involved. Hear how medical records impact reimbursement and more, how they help establish the physician from a quality standpoint, how they allow for continuity between subsequent providers, the biggest issue when it comes to m...

Send us Fan Mail What keeps you up at night in compliance? That’s the question Captain Integrity Bob Wade asks several compliance officers in this episode, recorded from the HCCA’s 29th Annual Compliance Institute in Las Vegas. Hear why you should go to conferences, the biggest concerns compliance officers have today, why we should be more open about compliance, the wide variety of compliance prof...

Send us Fan Mail Can you charge a payer lower than Medicare or Medicaid? In this episode, Captain Integrity Bob Wade explores when you can, and when you can’t. Hear why you need to look for the average or median of all expected payments, why you should remove the low and extravagant charges, how Medicare is not entitled to the lowest price you charge anyone, the origin of the most favored nation c...

Send us Fan Mail What’s a referral under the Stark Law and Anti-Kickback Statute (AKS)? In this episode, Captain Integrity Bob Wade dives into the definition. Hear what defines a referral, the 3 specialties that don’t refer, why a referral under the AKS is much broader in comparison with the Stark Law, the history of a famous saying, and the value of a memorable slogan. Learn more at CaptainIntegr...

Send us Fan Mail In Fiscal Year 2024, the federal government collected $2.9 billion in False Claims Act settlements (FCA). In this episode, Captain Integrity Bob Wade explains what happened. Hear how the qui tam bar is still active, why Stark Law and Fair Market Value issues (FMV) are still very big issues for compliance, how the Department of Justice (DOJ) gives you credit for cooperation & s...

Send us Fan Mail There are critical steps you need to take if you’re issued a Civil Investigative Demand (CID). In this episode, Captain Integrity Bob Wade explains how it works & what to do. Hear what happens if you fail to respond to a CID, why a legal hold is a must, how to be organized when submitting the documents, the difference between a CID and a subpoena, and some Fig Newtons nostalgi...

Send us Fan Mail Hospital-employed physicians can be investors in Ambulatory Surgery Centers (ASCs). In this episode, Captain Integrity Bob Wade wraps up his breakdown of ASCs. Hear what needs to happen for a physician to invest with a hospital in an ASC, why any items or services provided must be consistent with the safe harbors, how the Hospital-Physician ASC works, how many one-third income tes...

Send us Fan Mail All safe harbors require the one-third income test. In this episode, Captain Integrity Bob Wade continues his breakdown of Ambulatory Surgery Centers (ASCs). Hear how the one-third income test works, when a second one-third test is needed, what the Return on Investment (ROI) needs to be based on, the 4 types of ASCs safe-harbored under the Anti-Kickback Statute (AKS), and how to a...

Send us Fan Mail In the case of Ambulatory Surgery Centers (ASCs), the Stark Law does not apply. In this episode, Captain Integrity Bob Wade kicks off his breakdown of ASCs. Hear the pros & cons of ASCs from a patient’s perspective, why the Stark Law does not apply, why ASCs need to be billed under the composite rate, how block booking works for physicians, and the story of Bob’s daughter’s AC...

Send us Fan Mail  You don’t have to accept what is given to you. In this episode, Captain Integrity Bob Wade dives into Medicaid reimbursement litigation with Knicole Emanuel, Partner at Nelson Mullins. Hear why litigation is an option to fight low Medicaid rates, why you don’t need to accept the reimbursement rates presented, how medical equity works, the David vs. Goliath case Knicole worked on,...