Stark Integrity

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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 not violating the Anti-Kickback Statute, how to ensure your team understands the intent basis under the Anti-Kickback Statute, specific definitions to keep in mind, and what the Stark Law & Anti-Kickback Statute have to do with...

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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 some Miranda Lambert lyrics. Learn more at CaptainIntegrity.com 

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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’t technically perform all the services for a global payment, when it’s possible the physician could be compensated above fair market value (FMV), a little bit of wRVU math...

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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 necessity continues to be a very large focus, a shocking settlement involving a physician, and fun examples of things that just keep getting bigger. Learn more at CaptainIntegrity.com 

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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 the isolated transaction exception, and the history of the famous song, “All by Myself.” Learn more at CaptainIntegrity.com 

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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 & be cooperative, where cybersecurity fits in the Top 3 enforcement priorities for the False Claims Act, and how to go about vulnerability testing. Learn more at CaptainIntegrity.com 

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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 from June 2025, the certifications needed in cybersecurity, and some delicious candy bar history. Learn more at CaptainIntegrity.com 

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There are some exceptions to the broad definition of an ownership interest under the Stark Law. In this episode, Captain Integrity Bob Wade explains what are not ownership interests under the Stark Law. Hear why the definition does have exceptions, how most of the exceptions are deemed to be compensation arrangements, how to treat an unsecured loan, the 7 types of exceptions, and the original version of “The devil is in the details.” Learn more at CaptainIntegrity.com 

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Understanding the definition of an ownership interest is crucial under the Stark Law. In this episode, Captain Integrity Bob Wade shares why loans are ownership interests under the Stark Law. Hear why you need to know & understand all definitions under the Stark Law, why ownership interests also include loans & bonds under the Stark Law, why you should always self-report, key takeaways from a recent Stark Law settlement, and the history of the “When in Rome” proverb. Learn more at CaptainIntegrity.com

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Artificial Intelligence (AI) needs a little pushback. In Part 2 of this 2-part episode, Captain Integrity Bob Wade continues his talk on the intersection of AI, Fair Market Value (FMV), the Stark Law, and the Anti-Kickback Statute (AKS) with HealthValue Group Managing Partner Chris David. Hear why we need to be human to make AI helpful, how to protect your nonproprietary data AI can’t replicate, why survey data & valuation models are a commodity now, why AI won’t replace you as healthcare consultants, and an exercise involving a letter generated by Copilot. Learn more...

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Artificial Intelligence (AI) can save a lot of time, but you need to use it wisely. In Part 1 of this 2-part episode, Captain Integrity Bob Wade talks the intersection of AI, Fair Market Value (FMV), the Stark Law, and the Anti-Kickback Statute (AKS) with HealthValue Group Managing Partner Chris David. Hear how AI is already impacting the healthcare consulting industry, notable cases involving AI, the top use cases for AI tools, how AI-generated documents are viewed under the Stark Law, and whether the government is accepting AI. Learn more at CaptainIntegrity.com 

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Federally Qualified Health Centers (FQHCs) serve a medically underserved population. In this episode, Captain Integrity Bob Wade talks FQHCs, the Anti-Kickback Statute (AKS), and the Stark Law. Hear whether the Stark Law applies to FQHCs, the wide range of financial arrangements that can happen, why it’s important to document those financial arrangements, the most important rules & provisions to follow, and the history of the “pulling together” phrase. Learn more at CaptainIntegrity.com 

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Preparing expert witnesses for their testimony is an arduous process. In this episode, Captain Integrity Bob Wade dives into expert witness selection, preparing, and utilization with White Collar Crime Attorney Sean McKenna. Hear how to select the right expert witness, how to ensure the privileges are maintained, how to perform role playing during cross-examinations, the types of cases ripe for expert witnesses, and how to refute an expert witness. Learn more at CaptainIntegrity.com 

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Actively use Artificial Intelligence (AI). In Part 3 of this 3-part episode, Captain Integrity Bob Wade talks AI in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear why the implementation of AI technology will separate the winners & losers, how to explore AI applications as a Compliance Officer, how to think of AI governance like the development of a robust compliance program, the ties between AI governance & autonomous cars, and what AI use in healthcare will look like in 3-5 years. Learn more at CaptainIntegrity.com

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Being unbiased & fair is critical in the healthcare space. In Part 2 of this 3-part episode, Captain Integrity Bob Wade talks Artificial Intelligence (AI) in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear examples of how AI can be used in compliance, the key questions to put on the table, where there’s greater risk, whether it will eventually be considered malpractice if you’re not using AI in healthcare, and how worried compliance teams should be about bias with AI tools. Learn more at CaptainIntegrity.com

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Healthcare laws weren’t designed with artificial intelligence (AI) in mind. In Part 1 of this 3-part episode, Captain Integrity Bob Wade talks AI in healthcare law & compliance with Nelson Mullins Partners Bob Coffield & Darren Skyles. Hear where AI is already delivering real value in healthcare law & compliance today, the governance & risk management building blocks related to AI, the pros & cons of AI as it relates to existing healthcare laws, how AI compares to other tech revolutions over the years, and why AI might even be its own species. Learn more at CaptainIntegrity.com 

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Evaluating the effectiveness of a compliance program is a very important step. In this episode, Captain Integrity Bob Wade describes what a compliance effectiveness review is all about. Hear what the 8th element of an effective compliance program is, who should do the reviewing, why it’s all about culture, what Bob looks at in a review, and infamous examples where organizations failed to test effectiveness. Learn more at CaptainIntegrity.com 

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Build in time for back & forth. In this episode, Captain Integrity Bob Wade breaks down how to deliver bad news with Mimi Bliss, Leadership Communications Consultant with Bliss Communications. Hear the power of the pause, how to use starter or transition phrases, why you should keep it short & simple, what to do if an executive keeps interrupting you, and the key phrases to avoid. Learn more at CaptainIntegrity.com 

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This week’s Stark Integrity is a compilation of all the Christmas holiday specials from 2021-2025. Hear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” “Jolly OIG Agent,” “The 12 Days of Compliance,” and “Captain Integrity.” Share the poems with your team and learn more at CaptainIntegrity.com

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It’s time for the 2025 Stark Integrity podcast Christmas Special! In this special holiday episode, Captain Integrity Bob Wade reflects on 2025 and sings his latest custom Stark Law holiday carol, a “Santa Baby” parody. Hear Bob’s professional highlights from the year, the latest with his grandkids & Disney World, his accident involving a ladder, the history of “Santa Baby,” and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com 

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Audit results could lead to False Claims Act liability (FCA). In this episode, Captain Integrity Bob Wade talks through audits and potential FCA liability under the Stark Law. Hear why you should do probe audits, when you need to take corrective action, how to avoid the draconian fines & penalties under the FCA, famous cases involving the FCA, and not-so-funny examples of things that go from bad to very ugly. Learn more at CaptainIntegrity.com

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Some spouses may not know their financial arrangements may implicate the Stark Law. In this episode, Captain Integrity Bob Wade explains the marital considerations under the Stark Law. Hear when the Stark Law is implicated, why you need to train people who are approving payments to understand who owns the companies and their ties to physicians, how to exercise due diligence as it relates to the Stark law, just how broad the Stark Law can be, and entertaining marriage movies over the years. Learn more at CaptainIntegrity.com 

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You need to know what AI tools your organization is working with. In this episode, Captain Integrity Bob Wade dives into AI use (Artificial Intelligence) and guardrails in healthcare with Natalie Ramello, VP, Chief Compliance & Audit Officer, UT Southwestern Medical Center. Hear why integrity is the launchpad for innovation, how to protect the data, why AI requires accountability, why AI can hallucinate, and an AI-inspired rendition of Captain Integrity’s 3 Punch Points. Learn more at CaptainIntegrity.com

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Could “personally performed” services be compared to a self-driving vehicle? In this episode, Captain Integrity Bob Wade talks the parallels under the Stark Law. Hear why “personally performed” is frequently quoted in the Stark Law and Stark Law exceptions, what deems a service to be a referral, why a referral would not meet the Stark Law exceptions, whether the situation gets tricky, and Bob’s experience with a Zoox autonomous vehicle. Learn more at CaptainIntegrity.com

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TPE (Targeted Probe and Educate) audits look benign, but could be scary. In this episode, Captain Integrity Bob Wade explores TPE audits with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to know if you’re an outlier, the importance of responding timely, why the best defense is a strong offense, how a TPE audit works, and a bunch of things that look benign - but could kill you. Learn more at CaptainIntegrity.com 

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Interviews are key for risk assessment. In this episode, Captain Integrity Bob Wade dives into the value of compliance advisory support with Sheila Limmroth, Executive Consultant and Compliance Officer at Pinnacle Healthcare. Hear why advisory does not equal incompetence, how to grow from within, how to build a stronger compliance program, why no person or compliance program is perfect, and how nobody knows everything. Learn more at CaptainIntegrity.com

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Boo! In this special Halloween episode, Captain Integrity Bob Wade shares his original poem “Captain Integrity and the Curse of Stark Hallow” and a trip down Halloween costume history. Hear the most popular Halloween costumes from 1950-2005, the top Halloween costume on your birth year, Bob’s all-time favorite Halloween costume, the common theme with Halloween costumes over the years, and Bob’s special Halloween poem “Captain Integrity and the Curse of Stark Hallow.” Email Bob to get a printed copy of the poem and learn more at CaptainIntegrity.com

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 For every dollar of open payments money that goes into a hospital staff, there’s $7 of increase in spend on average to those firms. In this episode, Captain Integrity Bob Wade talks transparency & action as they relate to The 2025 Open Payments Report with Aaron Narva, CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts, how to know your healthcare data better than anyone else, how to use your healthcare data as a strategic advantage, why there’s a systemic problem, and the ice cream truck example. Learn more at Captain...

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If you’re going to give a gift to one physician, give it to all your physicians. In this episode, Captain Integrity Bob Wade rebroadcasts Part 3 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear an insightful Q&A session on non-monetary compensation and medical staff incidental benefits, how to handle gift certificates under the Stark Law, what to do when your organization is scared of being audited, the compliant way to give holiday gifts to physicians, and how to stay compliant when there’s a big dinner out...

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Doctors believe the medical staff funds are owned by them. In this episode, Captain Integrity Bob Wade rebroadcasts Part 2 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the benefits you can provide, how to handle lunches for doctors, the difference between employed & independent physicians as it relates to the Stark Law, value vs. cost considerations, and how to think about Joe on the street. Use code: CaptainIntegrity for a one-time $20 discount on a new AAPL membership and learn more at CaptainIntegrity.com 

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There’s a lot to consider when it comes to the Stark Law. In this episode, Captain Integrity Bob Wade rebroadcasts Part 1 of his webinar from September 5, 2025 with the American Association of Physician Liaisons (AAPL). Hear the basics of the Stark Law, notable exceptions, whether you can accept gifts in the healthcare industry, what to do if you’ve made a mistake in Stark Law compliance, and some Captain Integrity strips. Use code: CaptainIntegrity for a one-time $20 discount on a new AAPL membership and learn more at CaptainIntegrity.com

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The False Claims Act (FCA) has 3 knowledge qualifiers. In this episode, Captain Integrity Bob Wade unpacks the difference between actual knowledge, deliberate ignorance, and reckless disregard as it relates to the Stark Law. Hear why the 3 knowledge qualifiers exist, how risk impacts the False Claims Act, why you have to look at the history with respect to reviews, examples of the knowledge qualifiers with the healthcare compliance context, and that famous line from A Few Good Men. Learn more at CaptainIntegrity.com 

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Performing billing and documentation audits & reviews are important for an effective compliance program. In this episode, Captain Integrity Bob Wade explains what a probe review is and when you need to keep digging for a statistically valid review. Hear how to design your probe review using the RAT-STATS program, when you can treat your probe review as an educational review, when you need to do a statistically valid review, the history of RAT-STATS, and the origin of the “keep on digging” idiom. Learn more at CaptainIntegrity.com 

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The misuse of Modifier 25 can result in overcompensation if the physician is being compensated through a wRVU productivity model. In this episode, Captain Integrity Bob Wade lays out the connection between Modifier 25 and wRVUs as they relate to the Stark Law. Hear what questions to ask when it comes to Modifier 25, how to document separateness & significance, the connection between auditing for Modifier 25 and the Stark Law, the 4 criteria to use with Modifier 25, and the origin of Going the Extra Mile. Learn more at CaptainIntegrity.com 

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Don’t shoot the messenger. In this episode, Captain Integrity Bob Wade explores the nature of delivering bad news as a Compliance Officer & beyond. Hear how to deliver bad news, why you should soften the soil, how to use the sandwich approach when delivering bad news, the dangers of sugarcoating, and the history of the phrase Don’t Shoot the Messenger. Learn more at CaptainIntegrity.com 

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Auditor: you are not a Compliance Officer. In this episode, Captain Integrity Bob Wade dives into the complementary roles of Compliance Officer and Auditor. Hear the difference between the two roles, what each position is responsible for, why the roles are separate & distinct, the history of the Charles Horton Cooley looking-glass self quote, and some notable Hamilton lyrics. Learn more at CaptainIntegrity.com 

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Audit yourself. In this episode, Captain Integrity Bob Wade tackles the 2025 healthcare enforcement priorities with Brook Andrews, Partner at Nelson Mullins. Hear why healthcare enforcement is not going away, how the government’s healthcare enforcement tools will continue to get better, how to build a culture of transparency, who healthcare enforcement is targeting, and the parable of the blind men and the elephant. Learn more at CaptainIntegrity.com 

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If medical staff funds are in a hospital account, the Stark Law applies. In this episode, Captain Integrity Bob Wade details medical staff funds as they relate to the Stark Law. Hear when the Stark Law applies, why the medical staff funds are restricted, what to consider if the medical staff funds are not in a hospital account, the risks when it comes to medical staff funds, and  why this is a controversial topic. Learn more at CaptainIntegrity.com 

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If you’re paying your doctor for an hour of service, you better make sure your doctor is working an hour of service. In this episode, Captain Integrity Bob Wade breaks down what happens when financial arrangements exceed Fair Market Value (FMV). Hear why it’s important to keep tabs on your doctors, why monitoring is such a key component of compliance, what to do if financial arrangements exceed FMV, a case example of unethical billing practices, and the Top 10 PSA that inspired this episode. Learn more at CaptainIntegrity.com

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Healthcare providers should be concerned. In this episode, Captain Integrity Bob Wade explores the new DOJ and HHS False Claims Act Working Group targeting healthcare fraud with Knicole Emanuel, Partner at Nelson Mullins. Hear why you should review your compliance program, reassess your risk exposure, consider voluntary disclosure, the areas the working group is targeting, and why this is a paradigm shift for the healthcare industry. Learn more at CaptainIntegrity.com