Stark Integrity

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...

Send us Fan Mail It’s important to make compliance relevant, focused on ethical behavior, and fun. In this special holiday episode, Captain Integrity Bob Wade reveals how he got into Stark Law compliance in the first place and reads a custom Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Hear what Bob represents clients on, how to make compliance fun, celebrate the people you work...

Send us Fan Mail If a financial arrangement is unusual, it may not be commercially reasonable. In this episode, Captain Integrity Bob Wade details the key aspects of the commercial reasonableness standard and shares examples from real cases. Hear why commercial reasonableness is a qualitative analysis, how to think through if the financial arrangement makes sense, why it may not be commercially re...

Send us Fan Mail Value-based arrangements offer Fair Market Value freedom, but several challenges exist. In this episode, Captain Integrity Bob Wade details what value-based arrangements are and what they mean for your Stark Law cases. Hear why traditional Fair Market Value terms do not apply to value-based arrangements, continuous oversight and documentation is needed, what to do if you fail to m...

Send us Fan Mail Stark Law violations can lead to some incredibly serious settlements. In this episode, Captain Integrity Bob Wade shares recent Stark Law cases with severe payouts. Hear why million-dollar settlements have occurred, how to document the services being performed, the areas you can’t tie compensation to, the top non-structural Fair Market Value issues, and what Bob needs to say with...

Send us Fan Mail Where do you start when documenting Fair Market Value under the Stark Law? In this episode, Captain Integrity Bob Wade details everything from the starting point to key considerations. Hear why benchmark data makes a practical starting point, how to see if there’s alignment between productivity and total cash compensation, determine if there are subjective factors to support the t...

Send us Fan Mail Fair Market Value is a pinnacle issue when it comes to the Stark Law. In this episode, Captain Integrity Bob Wade explains the why, what, how, and beyond for Fair Market Value. Hear why Fair Market Value is a pinnacle issue, what methodology you can use to document Fair Market Value, what judgment factors to apply, the impacts on the lessor and lessee, and what caused a client to...

Send us Fan Mail Violations of the Stark Law can lead to some pretty serious damages, fines, and penalties. In this episode, Captain Integrity Bob Wade takes you through each with real-life examples. Hear why Stark Law damages can get so high, you should never create a circumvention scheme, what to do if you discover a Stark Law violation, the impact of the False Claims Act, and what Work RVUs are...

Send us Fan Mail What are the definitions under the Stark Law? In this episode, Captain Integrity Bob Wade takes you through The Big 5 Definitions under the Stark law and more. Hear why the Stark Law is so definitionally driven, how to know when the Stark Law applies, why it’s important to know the definitions, rare exceptions to the definitions, and specific examples. Learn more at CaptainIntegri...

Send us Fan Mail Does your healthcare organization have an effective compliance program? Captain Integrity is here to save the day. Welcome to Stark Integrity: The Stark Law and Compliance Podcast. In this pilot episode, you’ll meet host Bob Wade (aka Captain Integrity) and learn what the Stark Law is, the history of the Stark Law, and when it applies. As with every episode, you’ll come away with...