Stark Integrity

Send us Fan Mail Want to know what you get for The 12 Days of Compliance? In this special holiday episode, Captain Integrity Bob Wade reflects on 2024 and sings his latest custom Stark Law holiday carol, “The 12 Days of Compliance.” Hear the latest from Bob’s personal life & Nelson Mullins, his favorite things to do in Nashville, the history of “The Twelve Days of Christmas,” fun facts about t...

Send us Fan Mail If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck. In this episode, Captain Integrity Bob Wade shares how The Duck Test relates to wRVUs (work Relative Value Units) with Eric Leafgreen, VP of Provider Compensation at Ludi. Hear how to stabilize with oversight, how to embrace simplification through standardization, why you should do an a...

Send us Fan Mail During the 1st half of 2024, the Department of Justice’s enforcement activity collected over $1 billion. In this episode, Captain Integrity Bob Wade shares the focus of those DOJ settlements. Hear how the government is still collecting large settlements from providers, how qui tam relators are still bringing these cases to fruition, the importance of having an effective compliance...

Send us Fan Mail Use the data early & often. In this episode, Captain Integrity Bob Wade explores the intersection of data analytics & the False Claims Act (FCA) with Mandy Asgeirsson, Director at BRG (Berkeley Research Group). Hear why it’s really helpful to understand the data available in an FCA investigation, how to be creative in how you use the data to understand the case or allegati...

Send us Fan Mail Physician space sharing could be a great strategy - if you follow the rules. In this episode, Captain Integrity Bob Wade discusses physician space sharing as it relates to Stark Law compliance with Mike Vetter, Partner at HMS Valuation Partners. Hear why utilizing space sharing arrangements is a very cost-effective strategy for a healthcare system to expand services to other commu...

Send us Fan Mail Quality will always matter. In this episode, Captain Integrity Bob Wade discusses quality physician compensation as it relates to the Stark Law with Luis Argueso, Co-Founder & Partner at InHealth Advisors. Hear why quality matters, how to translate that importance of quality into effective incentives for healthcare providers, why there’s a lot of opportunity for innovation in...

Send us Fan Mail This is a fascinating moment in the history of the world. In this episode, Captain Integrity Bob Wade discusses social media and the online world as it relates to healthcare providers and the Stark Law with Mark Weinstein, Author of “Restoring Our Sanity Online” and Speaker of the hit TEDx talk, “The Rise of Surveillance Capitalism.” Hear why Big Tech is driving us mad and we have...

Send us Fan Mail What do The Addams Family, 1960s, OIG Agents, Medicare, and Halloween have in common? In this special Halloween episode, Captain Integrity Bob Wade explains the connection as it relates to the Stark Law. Hear all the ‘60s nostalgia you can handle, the history of The Addams Family and creator Charles Addams, the potential for a Captain Integrity TV show, the history of Medicare, an...

Send us Fan Mail Oh no - the dreaded overpayments. In this episode, Captain Integrity Bob Wade explores overpayment notices, mistakes, and the appeal process with Knicole Emanuel, Partner at Nelson Mullins. Hear why tentative notices of overpayments are scary but defensible, why you should know your right to appeal, the potential changes coming that may be in the providers’ best interest, why you...

Send us Fan Mail Is there such a thing as a free lunch in healthcare? In this episode, Captain Integrity Bob Wade gives you the rules, regulations, and requirements as it relates to the Stark Law. Hear why there’s no such thing as a free lunch, what you can do when there are service deficiencies, how to approach providing technology, recent cases that involve free lunches, and the history of free...

Send us Fan Mail “Bob, I think we have a big problem on our hands.” In this episode, Captain Integrity Bob Wade continues his discussion of the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear how to act with integrity, know when a case should be bifurcated, revamp your compliance program, why the DOJ got...

Send us Fan Mail And it all started with a Fair Market Value (FMV) defensibility analysis. In this episode, Captain Integrity Bob Wade discusses the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear why there should be heightened scrutiny with a Lone Wolf, why you need to pay special attention to a high pr...

Send us Fan Mail Let’s go Back to the Future. In this episode, Captain Integrity Bob Wade “time travels” to all things Chevron deference with Phillip Mullinnix, Partner at Nelson Mullins. Hear why prior court rulings are up for grabs, where to expect more litigation, where to expect lengthy legislation, the history of the Chevron case, and some Back to the Future movie trivia. Learn more at Captai...

Send us Fan Mail Emails are evil. In this episode, Captain Integrity Bob Wade explores the new compliance risk of algorithmic pricing with fan-favorite Bart Daniel, Partner at Nelson Mullins. Hear why you should beware of algorithmic pricing, beware of Private Equity (PE), examine the reimbursement rates closely, how to turn your expense department into a revenue department, and why enforcing algo...

Send us Fan Mail The Improbable Day or Impossible Day is a major compliance issue. In this episode, Captain Integrity Bob Wade chats these scenarios with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to avoid an Improbable Day or Impossible Day scenario, why you should do scheduling audits, why the best defense is a strong offense, the biggest red flags with these scenarios, and a l...

Send us Fan Mail Data is endlessly impactful in the healthcare space. In this episode, Captain Integrity Bob Wade discusses open payments and compliance findings with Aaron Narva, Co-Founder and CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts in your organization, how your data is available and under scrutiny, why understanding your data can be your secret weapon, so...

Send us Fan Mail A referral by a physician of a Designated Health Service (DHS) is the key to opening up the Stark Law City. In this episode, Captain Integrity Bob Wade explains what a DHS is and how they’re categorized. Hear why you should add the CMS (Centers for Medicare & Medicaid Services) website page about the Stark Law to your Favorites, which Stark Law categories are defined by the CP...

Send us Fan Mail Move it to an asset rather than a liability. In this episode, Captain Integrity Bob Wade talks Corporate Integrity Agreements (CIAs) and Independent Review Organizations (IROs) with Harriett Wall, President and CEO of LW Consulting, Inc. Hear how to avoid CIAs with a strong compliance program, why an IRO should be open to input, how to embrace a CIA for change, whether an OIG Moni...

Send us Fan Mail Data is a big driver of a lot of cases. In this episode, Captain Integrity Bob Wade breaks down the press release and results from the Criminal National Health Care Fraud Enforcement Action in 2024 with Jillian Willis, Partner at Nelson Mullins. Hear how data analytics remain at the forefront of detecting and prosecuting healthcare fraud, why criminal healthcare fraud enforcement...

Send us Fan Mail Monitoring is a crucial piece of compliance. In this episode, Captain Integrity Bob Wade discusses documenting monitoring efforts with James Rose, Managing Director of SunHawk Consulting. Hear how to provide an annual attestation of compliance, how to build controls and oversight into the business, the difference between auditing and monitoring, where to start when it comes to mon...

Send us Fan Mail Crises happen all the time. In this episode, Captain Integrity Bob Wade talks next generation root cause analysis with James Rose, Managing Director of SunHawk Consulting. Hear why you should never let a good crisis go to waste, follow up on big near-misses, look at root cause analysis from multiple angles, the background behind root cause analysis, and the biggest mistakes in Six...

Send us Fan Mail What was the Correlation Theory under the Stark Law? In this episode, Captain Integrity Bob Wade explains what it was and how it differs from the Volume or Value Varying Standard and Volume or Value Determination Standard. Hear why the Correlation Theory is dead, when it can still be a valid theory, what to focus on when it comes to Volume or Value, what happened in the Bookwalter...

Send us Fan Mail Compensating Key Opinion Leaders (KOLs) or thought leaders is a little different than regular physician compensation. In this episode, Captain Integrity Bob Wade walks you through how to evaluate KOL compensation. Hear why not every physician is a KOL, why you need to look at the services requested to be performed, how everything boils down to an hourly rate, the importance of the...

Send us Fan Mail Are percentage-based compensation arrangements permitted under the Stark Law? In this episode, Captain Integrity Bob Wade explores the answer. Hear the circumstances where percentage-based compensation arrangements are permissible, why they’re prohibited when it comes to office space or equipment rentals, the difference between percentages and percentage points, the most common ex...

Send us Fan Mail To per-click or not to per-click? That is the question. In this episode, Captain Integrity Bob Wade breaks down all things per-click arrangements under the Stark Law. Hear why per-click arrangements are permissible under limited circumstances, how it works with lessors and lessees, what you can bundle together, the most common misconceptions about per-click arrangements, and every...