Stark Integrity

Send us Fan Mail Silence. In this episode, Captain Integrity Bob Wade explains why that is the most dangerous sound in healthcare compliance. Hear why silence is data, how non-retaliation is a compliance control requirement, what the board’s job is when it comes to healthcare compliance, the earliest warning system in healthcare compliance, and the top reasons employees go quiet. Learn more at Wad...

Send us Fan Mail Prevention really helps avoid much bigger problems down the road. In this episode, Captain Integrity Bob Wade explores the False Claims Act (FCA) with an international spin with Nelson Mullins Partner Christina Lehm. Hear why you should follow the government money, how to take internal concerns seriously and act early, how to treat litigation readiness as part of your business str...

Send us Fan Mail A new chapter: Wade Health Law. But, the same compass. In this episode, Captain Integrity Bob Wade introduces his new law firm, Wade Health Law. Hear why he’s starting his own law firm, 4 stories that have shaped his personal life & professional career, the most important lessons he’s learned in life & healthcare law, why change is inevitable, and what to expect in future...

Send us Fan Mail We’re not talking about conversion factors as they relate to the 2027 Medicare Physician Fee Schedule (MPFS) and proposed rules. In this episode, Captain Integrity Bob Wade focuses primarily on how the 2027 MPFS may impact physician compensation and Fair Market Value (FMV) in the future. Hear why the 2027 MPFS means a lot more with respect to physician compensation, how the Center...

Send us Fan Mail There are 3 primary tests under the Stark Law: Fair Market Value (FMV), the Volume or Value standard, and Commercial Reasonableness (CR). In this episode, Captain Integrity Bob Wade dives deep into the Commercial Reasonableness standard. Hear why Commercial Reasonableness is fundamentally about a legitimate business purpose, the right questions to ask in terms of Commercial Reason...

Send us Fan Mail In the 2027 Physician Fee Schedule, CMS (Centers for Medicare & Medicaid Services) is proposing modifications for procedures and E&M services (Evaluation & Management) performed on the same day. In this episode, Captain Integrity Bob Wade describes what is being proposed as it relates to the Stark Law. Hear what is not going away, why the proposal is a payment methodol...

Send us Fan Mail Having someone who is accountable is essential for AI governance. In this episode, Captain Integrity Bob Wade discusses implementing & monitoring AI responsibly as it relates to the Stark Law with Arvita Tripati, Founder & Principal at Vahana Labs. Hear why buying technology does not outsource the accountability, why you need to ask every vendor when the tool was last vali...

Send us Fan Mail Compliance committees can either be a well-oiled engine in a Lamborghini, or an engine being held up by an engine hoist in need of repair. In this episode, Captain Integrity Bob Wade shares how to run and participate in a compliance committee meeting that actually matters. Hear why a compliance committee should ask questions, how to focus on the fire instead of the smoke, why ever...

Send us Fan Mail Why are private equity, physician groups, and the Stark Law like insects heading to a bug zapper? In this episode, Captain Integrity Bob Wade explains why. Hear why ownership changes do not eliminate Stark Law risk, why compensation redesign deserves careful attention, why documentation is your best defense, the mother of all definitions, and the research behind insects being attr...

Send us Fan Mail You can now experience Stark Integrity in 2 ways: the podcast AND the blogs. In this episode, Captain Integrity Bob Wade introduces the Stark Integrity Podcast Blogs, where you can enjoy each episode as 1 conversation, with 2 experiences. Hear what to expect with the new Stark Integrity website, how your favorite Stark Integrity topics & episodes are now searchable, the goal o...

Send us Fan Mail In a recent episode of Stark Integrity, Captain Integrity Bob Wade made an incorrect statement regarding Erlanger Health and a Stark Law case. In this brief update, he sets the record straight. Learn more at CaptainIntegrity.com  

Send us Fan Mail Lean in wherever you have quick wins. In this episode, Captain Integrity Bob Wade talks using AI in physician contracting & payment as they relate to the Stark Law with Scott Lowry, Founder of StarkWatch. Hear how to quickly assess where your organization’s at with its Stark Law compliance program, how to aim for advancement instead of program perfection, why you should use in...

Send us Fan Mail Training goes a long way when it comes to informed consent. In Part 3 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear why you need to document the decision-making capacity, how to make sure AI use is properly disclosed, why policies & procedures p...

Send us Fan Mail The more checks and balances an organization has along the way, the greater the protection for both the patients & the providers. In Part 2 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear how decision-making capacity & inadequate informed cons...

Send us Fan Mail The patent’s right to autonomy is one of the core principles of the patient-provider relationship. In Part 1 of this 3-part episode, Captain Integrity Bob Wade talks informed consent, decision-making capacity, and surrogates as they relate to the Stark Law with Attorney Rachel Rose. Hear the recent cases where informed consent & decision-making capacity were relevant, the diff...

Send us Fan Mail You should be able to duct tape your mouth & hands and give your documentation to the payer, and they should still be able to generally understand what happened. In Part 2 of this 2-part episode, Captain Integrity Bob Wade continues his discussion on holistic audits and synchronizing professional & facility reviews under the Stark Law with Kelly Loya & Bruce Truitt of...

Send us Fan Mail You can’t audit the whole ocean. In Part 1 of this 2-part episode, Captain Integrity Bob Wade discusses holistic audits and synchronizing professional & facility reviews under the Stark Law with Kelly Loya & Bruce Truitt of Pinnacle Enterprise. Hear what holistic audits are, the different types of reviews, the benefits of sampling a patient encounter, how to maintain an un...

Send us Fan Mail There is indeed a return on investment (ROI) for an effective compliance program. In this episode, Captain Integrity Bob Wade quantifies that ROI as it relates to the Stark Law. Hear why the ROI can be 2x-5x what the organization is investing, how the cost for non-compliance is 2x-3x higher, why you shouldn’t look at the compliance program as just a cost center, examples of compli...

Send us Fan Mail When analyzing a physician financial arrangement under the Stark Law, you also need to analyze it under the Anti-Kickback Statute (AKS). In this episode, Captain Integrity Bob Wade explains why most of the exceptions under the Stark Law cross-reference the Anti-Kickback Statute. Hear all about the Stark Law & Anti-Kickback Statute dance, the 3 ways to meet the definition of no...

Send us Fan Mail The definition of an “Entity” under the Stark Law includes Managed Care Organizations (MCOs) and the Anti-Markup Rule. In this episode, Captain Integrity Bob Wade details this “Entity” definition under the Stark Law. Hear who the “Entity” usually is, why they expanded the definition, the very narrow exception they came up with, examples of an “Entity” in action, and Bob recite som...

Send us Fan Mail When a physician doesn’t perform 100% of the services covered by a surgical period, you may have to consider splitting out the global wRVUs. In this episode, Captain Integrity Bob Wade talks global wRVUs and personally performed services as they relate to the Stark Law. Hear the 3 separate categories when a service is covered by a global payment, what happens when a physician didn...

Send us Fan Mail False Claims Act settlements (FCA): they just keep getting bigger. In this episode, Captain Integrity Bob Wade details the notable False Claims Act settlements for 2025. Hear how qui tam cases continue to represent the largest source of settlements through the Department of Justice (DOJ) and False Claims Act, what it means if the government declines to intervene, why medical neces...

Send us Fan Mail There are some uses of the isolated transaction exception that are prohibited under the Stark Law. In this episode, Captain Integrity Bob Wade dives into that isolated transaction exception. Hear why the isolated transaction exception has been expanded, the times when it can be used for service arrangements, how it can be used for settlement of a bona fide dispute, the nuances of...

Send us Fan Mail Beware of the enemy within. In Part 2 of this 2-part episode, Captain Integrity Bob Wade talks cybersecurity and the False Claims Act (FCA) with returning guest and Nelson Mullins Partner Bart Daniel. Hear how to guide outside contractors through certification, why you need to monitor & protect any vulnerabilities as they arise, how to disclose any shortcomings when discovered...

Send us Fan Mail Cybersecurity and the False Claims Act (FCA) have more in common than you think. In Part 1 of this 2-part episode, Captain Integrity Bob Wade talks cybersecurity and the False Claims Act with returning guest and Nelson Mullins Partner Bart Daniel. Hear the history of the False Claims Act, fascinating stats on whistleblowers, the impact of Trump’s executive order on cybersecurity f...