Stark Integrity

Send us Fan Mail We have a chicken and egg problem. In this episode, Captain Integrity Bob Wade welcomes Anthony Domanico of VMG Health to recap what they learned and discussed at the recent AAPCP Conference (American Association of Provider Compensation Professionals). Hear what makes the AAPCP a great organization, why compensation compliance under the Stark Law and Anti-Kickback Statute covers...

Send us Fan Mail Under the Stark Law, hospitals can financially induce physicians. In this episode, Captain Integrity Bob Wade continues his analysis on physician recruiting under the Stark Law. Hear why incremental expenses are a major factor with physician recruitment, community need is a requirement for tax-exempt hospitals, you need to monitor these arrangements, the impact of a HPSA (Health P...

Send us Fan Mail Under the Stark Law, hospitals can financially induce physicians. In this episode, Captain Integrity Bob Wade starts his analysis on physician recruiting under the Stark Law. Hear how to study and apply the strict definitions, why physicians always have to sign the agreement, there’s no Fair Market Value or Commercial Reasonableness requirement specifically stated in the Physician...

Send us Fan Mail How do you know? Where’s the proof? In this episode, Captain Integrity Bob Wade welcomes Lucia Pizano-Urbina of Broward Health to chat about life operating under a Corporate Integrity Agreement and the world of Compliance. Hear how to create a CIA Annual Report Subcommittee, always have a plan of correction for any item, be organized, learn the CIA (Corporate Integrity Agreement)...

Send us Fan Mail If you believe you are a Group Practice, let’s do the Group Practice dance. In this episode, Captain Integrity Bob Wade continues the discussion on Group Practice under the Stark Law. Hear how to know what type of facility in which the services are provided, the difference between ancillary services and incident to services, why multimillion-dollar settlements have occurred in thi...

Send us Fan Mail Physician fee schedules change frequently. In this episode, Captain Integrity Bob Wade welcomes Bob Madden of SullivanCotter to break down the latest changes in wRVUs and their impact. Hear why you should be very careful when selecting a comparative group from the available benchmark data, keep key considerations in mind, prepare yourself for changes to come, why there were some a...

Send us Fan Mail The group practice definition under the Stark Law is the mother of all Stark Law definitions. In this episode, Captain Integrity Bob Wade shares the detailed definitions and subdefinitions of Group Practice under the Stark Law. Hear how to understand each subdefinition, how members of a group practice differ from physicians, what happens if you don’t meet all definitions, surrogat...

Send us Fan Mail 2020 and 2021 will have a long-term impact on Stark Law Compliance. In this episode, Captain Integrity Bob Wade details how the massive changes of the past couple years impact Fair Market Value and Stark Law Compliance. Hear the double whammy on physician compensation caused by COVID and the Physician Fee Schedule, why you need to be very careful in looking at total compensation,...

Send us Fan Mail There are many lessons to learn from the 2021 False Claims Act settlements. In this episode, Captain Integrity Bob Wade recaps the major settlements under the False Claims Act in 2021 and what actionable insights we can pull from them. Hear why the qui tam weapon is still a large tool for the Department of Justice, healthcare is the largest source of false claims recovery for the...

Send us Fan Mail Value equals Benefit divided by Risk. In this episode, Captain Integrity Bob Wade welcomes Coker Group SVP Richard Romero to discuss the ins and outs of business valuations. Hear the 4 universal laws of valuation, how to make sure the standard of value applies to your situation, understand capacity constraints of your people and assets, when valuations come into play, and Richard’...

Send us Fan Mail How does the Stark Law sausage get made? In this episode, Captain Integrity Bob Wade welcomes Parkview Health Associate General Counsel Alex Krouse to break down his experience and advice for Stark Law compliance. Hear how to develop teams and processes for provider compensation, consider several factors as you shape your organization, lean on the structure you set up, what the da...

Send us Fan Mail As a Board member, you need to have effective oversight of the fraud and abuse statutes. In this episode, Captain Integrity Bob Wade continues the discussion on what you need to know as a Board member for Stark Law compliance. Hear the the 5 main statutes of fraud and abuse, how to ensure your organization has a regimented process to validate compliance, why you need to be comfort...

Send us Fan Mail 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...

Send us Fan Mail 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 care...

Send us Fan Mail 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...

Send us Fan Mail 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...

Send us Fan Mail 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...

Send us Fan Mail 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 conside...

Send us Fan Mail 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 consid...

Send us Fan Mail 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 b...

Send us Fan Mail 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,...

Send us Fan Mail 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...

Send us Fan Mail The dreaded non-monetary compensation exception can get pretty tricky. In this episode, Captain Integrity Bob Wade discusses what items meet the non-monetary compensation exception under the Stark Law, including real-life examples. Hear why the definition of remuneration plays a key part, it’s essential to track non-monetary compensation on an annual basis, how to track the value...

Send us Fan Mail Hear Captain Integrity Bob Wade read his original Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Share the poem with your team and learn more at CaptainIntegrity.com

Send us Fan Mail It’s important to understand the differences between ownership and compensation arrangements - both direct and indirect. In this episode, Captain Integrity Bob Wade breaks down the differences between each under the Stark Law, and where various exceptions apply. Hear how to draw out the various arrangements to determine what’s what, look at downward ownership in the chain, the def...