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Stark Integrity

Author: Bob Wade

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Does your healthcare organization have an effective compliance program? Captain Integrity is here to save the day. Learn how to roll out necessary, lighthearted, and fun education to your employees and physicians so they abide by Stark Law. Hosted by Bob Wade aka Captain Integrity, award-winning Healthcare Regulatory and Stark Law Attorney

124 Episodes
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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 everything from Shakespeare to Sesame Street. Learn more at CaptainIntegrity.com
It’s an evolving industry. In this episode, Captain Integrity Bob Wade breaks down compensation learnings from the AAPCP (American Association of Provider Compensation Professionals) Annual Conference with Chris Fete, Partner at Pinnacle Healthcare Consulting (PHC). Hear why the growth and involvement of AAPCP is important for the industry, why the AAPCP credential is a good thing, how to stay on top of trends, what to think of AI in the healthcare space, and some fun perks of this year’s con...
How do you identify covert retaliation? In this episode, Captain Integrity Bob Wade reveals 8 categories of covert retaliation as they relate to the Stark Law. Hear the 2 broad categories of retaliation, how the anti-retaliation provisions under the False Claims Act (FCA) are separate causes of action an individual can bring against entity and individuals, why covert retaliation is the most challenging form of retaliation to identify, the origins of retaliation, and how it differs when it com...
Billions of dollars are spent on marketing in the healthcare sector each year. In this episode, Captain Integrity Bob Wade explains why such marketing can cause issues under the Stark Law and Anti-Kickback Statute (AKS). Hear why marketing between referral sources is not illegal, you need to look at the development and placement of the advertisement, Fair Market Value (FMV) is king, the typical amount different medical specialties spend each month on marketing, and the different types of ads ...
Does the Stark Law have a de minimis compensation exception? In this episode, Captain Integrity Bob Wade explores whether one exists. Hear what a de minimis compensation exception means, why the compensation must still be Fair Market Value (FMV) and Commercially Reasonable (CR), why you don’t need to have a written agreement after the fact, examples from the world of the Stark Law, and a brief history lesson on exceptions. Learn more at CaptainIntegrity.com
Understanding a wRVU (work Relative Value Unit) might feel like searching for the Holy Grail. In this episode, Captain Integrity Bob Wade explains what a wRVU is. Hear why you need to understand what a wRVU is, why work effort is a component, how to avoid the pitfalls with wRVUs, some of the many acronyms in the healthcare industry, and a classic Monty Python story. Learn more at CaptainIntegrity.com
The Volume or Value Restriction under the Stark Law is a conundrum. In this episode, Captain Integrity Bob Wade breaks down how to approach compensation under the Stark Law. Hear why aggregate compensation can vary, why you can use the same analysis under the safe harbors under the Anti-Kickback Statute (AKS), why you should keep your compensation determination process separate, how volume and value are determined, and when to use volume or value. Learn more at CaptainIntegrity.com
Telehealth is here to stay. In this episode, Captain Integrity Bob Wade continues his discussion on telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how to think through which encounters would benefit from telehealth, why consent is so important, why prevention is key, the guidance on coding and billing, and what the future of telehealth will look like. Learn more at CaptainIntegrity.com
Telehealth should be a service that is used to diagnose and treat a patient. In this episode, Captain Integrity Bob Wade talks telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how telehealth works, new legislation that affects telehealth, compliance risks associated with telehealth, how Christine’s love for telehealth goes back to The Jetsons, and some fun stories from the conference in Alaska. Learn more at...
Make sure documentation related to physician financial arrangements helps you, not hurts you. In this episode, Captain Integrity Bob Wade shares how this documentation can work to your advantage. Hear why training is critical, why you should look at your documentation through the eyes of the Department of Justice (DOJ), Officer of Inspector General (OIG), or a qui tam relator, how to do periodic audits or reviews, who to include on emails, and how to know the waters of the negotiating pool. L...
The DOJ (Department of Justice) collected $2.68 billion under the False Claims Act (FCA) in Fiscal Year 2023. In this episode, Captain Integrity Bob Wade recaps the latest interesting stats from FCA settlements. Hear why the FCA is still a very vital weapon for the government to pursue fraud, how healthcare made up 67% of the FCA settlements in Fiscal Year 2023, qui tam relators brought 86% of settlements, other record-setting numbers from the year, and a nod to Carl Sagan’s Billions & Bi...
Fair Market Value (FMV) and Commercial Reasonableness (CR) are separate concepts, but overlap. In this episode, Captain Integrity Bob Wade talks all things FMV vs. CR. Hear why CR is not one of value, it has 2 components, where the overlaps exist, Bob’s pie analogy, and what factors to consider. Learn more at CaptainIntegrity.com
Under the Stark Law, entities with medical staffs can pay for treatment and promotion of mental health. In this episode, Captain Integrity Bob Wade dives into the tough topics of substance abuse and addiction as they relate to the Stark Law. Hear why we’re all addicted to something, the new exception under the Stark Law, why the exception is a good thing, the 5 characteristics of an addiction, and which medical profession has the highest burnout rate. Learn more at CaptainIntegrity.com
Commercial Reasonableness is like a pie. Fair Market Value (FMV) is like a slice of the pie. In this episode, Captain Integrity Bob Wade discusses the latest on FMV under the Stark Law with Tim Smith, Principal at TS Healthcare Consulting. Hear why you need to study the regs, start doing economic analysis, start developing in-house expertise in this area, what you need to say loudly and clearly, and insights from Tim’s book, “The Complete Guide to Fair Market Value Under the Stark Regulations...
If you’re able to meet in the middle, you can share the risk. In this episode, Captain Integrity Bob Wade covers employing hospital-based specialists with Joe Aguilar and Natalie Bell, Partners at HMS Valuation Partners. Hear why you need to do the math, you should consider sharing the risk, what happens once you take the leap, how to determine the stipend, and revenue cycle management. Learn more at CaptainIntegrity.com
Look at your policies and make sure they’re up to date. In this special episode, Captain Integrity Bob Wade wraps up his discussion on insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 3 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on January 9, ...
You need to make sure you’re providing accurate information. In this special episode, Captain Integrity Bob Wade continues his discussion on insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 2 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on Janua...
A complaint is just a complaint. In this special episode, Captain Integrity Bob Wade discusses insights from the Community Health Network $345MM settlement with Tim Smith, Principal at TS Healthcare Consulting, and Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 1 of a 3-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on January 9, 2024. Hear the timeline of the settlemen...
If you have bad news to share, you share it yourself - and own it. In this episode, Captain Integrity Bob Wade discusses crisis communication management with Eileen Wixted, Principal at Wixted & Co. Hear why it’s all about how you respond, why it’s important to be truthful, how to build trust through communication, the different types of crises, and how to determine a communication strategy. Learn more at CaptainIntegrity.com
You’re more powerful than you think. In Part 2 of this special interview, Captain Integrity Bob Wade continues his discussion of one of the most infamous compliance stories in recent history with Frances Haugen, the Facebook whistleblower, Founder of Beyond the Screen, and Author of “The Power of One.” Hear how your life might change once you became a whistleblower, whether it’s worth it, her advice to employees who discover unethical behavior, the pros and cons of holding a secret, and how t...
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