Stark Integrity

Send us Fan Mail Healthcare transactions are different from ordinary transactions. In this episode, Captain Integrity Bob Wade discusses the issues we should be focusing on in the healthcare space. Hear how to ensure the arrangement is Fair Market Value (FMV), why you should purchase assets, when not to assume liability for physicians, the biggest transactional issues in the healthcare space, and...

Send us Fan Mail There’s been a fascinating shift to value-based reimbursement arrangements from those based on production. In this episode, Captain Integrity Bob Wade discusses trends and issues in that space with Christine Worthen, Partner at Nelson Mullins. Hear why you should consider your strategic planning for the glide path to risk, look at the regulatory addendum and negotiate it, always h...

Send us Fan Mail Creating a tagline, slogan, or logo could be an effective way to market and promote your compliance program. In this episode, Captain Integrity Bob Wade dives into the marketing of your compliance program. Hear how a logo helps promote the identification of your compliance program, why it should be consistently used, why it doesn’t ensure an effective compliance program on its own...

Send us Fan Mail Unfortunate statements and emails can trigger a long and expensive journey for an organization. In this episode, Captain Integrity Bob Wade discusses the Greber and Holland cases as they relate to the One Purpose test with Gabe Imperato, longtime friend and Partner at Nelson Mullins. Hear why the U.S. v. Holland case is a significant decision, the court looked for evidence of will...

Send us Fan Mail Waiving copays and deductibles has to be performed in a specific manner. In this episode, Captain Integrity Bob Wade details the ins and outs of waiving copays. Hear why the routine waiver of copays and deductibles can be illegal, you can waive them in certain instances, what will cause a claim to be overstated, what exactly a copay waiver is, and examples from recent cases. Learn...

Send us Fan Mail There’s an interesting issue with respect to the amount of the collections in 2022. In this episode, Captain Integrity Bob Wade highlights the learning points from the DOJ (Department of Justice) 2022 False Claims Act (FCA) Settlements and Judgments. Hear why the qui tam bar still represents the largest dollar amount of settlements, individual accountability is still occurring, we...

Send us Fan Mail One of the most effective parts of a compliance program is to have a compliant culture. In this episode, Captain Integrity Bob Wade breaks down how to foster a culture of compliance. Hear why an ethical culture starts at the top, how to understand the culture of an organization, what to do if you believe your organization is making unethical decisions, how to measure the effective...

Send us Fan Mail The new rules create new standards that reduce compliance risk. In this episode, Captain Integrity Bob Wade discusses the key issues in value-based arrangements with Kelly Conroy, Principal at Pinnacle Healthcare, and Ed White, Partner at Nelson Mullins. Hear why now is the time to start your value-based care strategy, value-based enterprises can be used as a strategy for provider...

Send us Fan Mail Physicians may believe a test or procedure is medically necessary, but payers make the final determination. In this episode, Captain Integrity Bob Wade details medical necessity and the implications for Stark Law compliance. Hear why payers make the medical necessity determination, patients are in control, we can compensate a physician if the patient desires additional services, w...

Send us Fan Mail How do you audit practically? In this episode, Captain Integrity Bob Wade breaks down the Who, What, and How of audit work plan development under the Stark Law. Hear why you shouldn’t do it alone, how to look at the government resources out there, use some type of numerical weighting to assess risks, why auditing isn’t rocket science, and a sausage analogy from Bob. Learn more at...

Send us Fan Mail Make sure that management fee is in order. In this episode, Captain Integrity Bob Wade talks Corporate Practice of Medicine (CPOM) compliance with Heather Miller, Healthcare Transactional and Regulatory Lawyer at Nelson Mullins. Hear why you need to substantiate the management fee in your paperwork, stick with a flat management fee, check state laws on leasing, how CPOM ties to th...

Send us Fan Mail Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena” and “Rudy the Seasoned Compliance Officer.” Share the poems with your team and learn more at CaptainIntegrity.com

Send us Fan Mail This year has been full of change, and I want to wish you all a great holiday season. In this special holiday episode, Captain Integrity Bob Wade reflects on change in 2022 and reads a custom Stark Law holiday poem, “Rudy the Seasoned Compliance Officer.” Hear the good and bad changes that came about this year, how it feels to attend and speak at in-person conferences again, signi...

Send us Fan Mail Be an expert in your field. In this episode, Captain Integrity Bob Wade talks compliance program development and effectiveness with Steve Sugrue, Chief Compliance Officer of DocGo. Hear why you should hire people smarter than you, always be relentlessly in pursuit of best practices, seriously consider an approach towards ESG (Environmental, Social, and Governance), how big your co...

Send us Fan Mail Use your superpowers in the field of compliance. In this episode, Captain Integrity Bob Wade talks value creation in the world of compliance with Jerry Shafran, Founder and Chief Executive Officer of YouCompli. Hear how to channel your inner salesperson, simplify, be an instigator of change, what sales and compliance have in common, and the reputation of compliance professionals....

Send us Fan Mail Can we really throw Fair Market Value (FMV) out the window? In this episode, Captain Integrity Bob Wade revisits Value-Based Arrangements with a special focus on mistakes that can be made. Hear why Value-Based Arrangements through the Safe Harbor and the Exception are a beautiful thing, it’s critical the governing body meet regularly and review the criteria, what happens if you do...

Send us Fan Mail Believe it or not, the Stark Law involves charitable contributions by physicians and immediate family members. In this episode, Captain Integrity Bob Wade explains the rules of charitable contributions as they relate to the Stark Law. Hear why remuneration plays a key role, charitable contributions cannot be solicited or offered by a physician who takes into account the volume or...

Send us Fan Mail Legal Independent Review Organizations (IRO) are usually required under Corporate Integrity Agreements when physician financial arrangements are involved in the settlement - but you don’t have to use a LIRO in only Corporate Integrity Agreements. In this episode, Captain Integrity Bob Wade breaks down the world of LIROs when it comes to the Stark Law. Hear why a LIRO has to be ind...

Send us Fan Mail Thorough documentation can go a long way under the Stark Law. In this episode, Captain Integrity Bob Wade continues to dive into the Medicaid-Stark Law pool - this time with special guest Andy Lenobel, Associate General Counsel at Nationwide Children’s Hospital. Hear why you need to show your work, follow your policy, learn to love the endless nature of compliance, Andy’s view fro...

Send us Fan Mail Does the federal Stark law apply to state Medicaid reimbursement? In this episode, Captain Integrity Bob Wade outlines why it doesn’t really matter - as he dives into the Medicaid-Stark Law pool. Hear why there’s still an argument whether hospitals violate the federal Stark Law when they submit Medicaid claims, many states still have their own Stark Law statutes and regulations, F...

Send us Fan Mail Determining where a physician’s conduct should be reviewed is a challenging subject. In this episode, Captain Integrity Bob Wade continues his breakdown of Peer Review and Compliance in relation to the Stark Law. Hear why quality can be both a Peer Review and a Compliance issue depending on the severity, fraud issues that impact billing are usually the exclusive domain of the Comp...

Send us Fan Mail Physician activities reviewed through the Peer Review process may pose liability under the False Claims Act - including the Stark Law. In this episode, Captain Integrity Bob Wade details how Peer Review and Compliance can work together. Hear how to train your team on Peer Review and Compliance issues, why Peer Review documents can be reviewed by other appropriate individuals in th...

Send us Fan Mail Jury trials under the False Claims Act (FCA) can produce very wild outcomes. In this episode, Captain Integrity Bob Wade breaks down what went down in the recent Eli Lilly/Astellas Pharma case. Hear why jury trials under the FCA are extremely rare, there are large jury verdicts, an effective compliance program can reduce or eliminate the risk of going to court, how big a return th...

Send us Fan Mail The False Claims Act (FCA) continues to be a huge weapon for the government. In this episode, Captain Integrity Bob Wade details the FCA settlements that have happened so far in 2022. Hear why there are still very large settlements that have occurred under the FCA, the knowledge requirement under the FCA is very broad, Corporate Integrity Agreements (CIAs) and Qui Tam Relators wer...

Send us Fan Mail Accountable Care Organizations (ACOs) are truly unique partnerships with the government. In this episode, Captain Integrity Bob Wade welcomes Kelly Conroy of Pinnacle Healthcare Consulting to chat the ins and outs of ACOs as they relate to the Stark Law. Hear why every primary care physician (PCP) should be in an ACO, almost every big commercial carrier has a shared savings compon...