Stark Integrity

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What keeps you up at night in compliance? That’s the question Captain Integrity Bob Wade asks several compliance officers in this episode, recorded from the HCCA’s 29th Annual Compliance Institute in Las Vegas. Hear why you should go to conferences, the biggest concerns compliance officers have today, why we should be more open about compliance, the wide variety of compliance professionals & healthcare organizations that attend the Compliance Institute, and the most surprising compliance issues to watch out for. Learn more at CaptainIntegrity.com 

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Can you charge a payer lower than Medicare or Medicaid? In this episode, Captain Integrity Bob Wade explores when you can, and when you can’t. Hear why you need to look for the average or median of all expected payments, why you should remove the low and extravagant charges, how Medicare is not entitled to the lowest price you charge anyone, the origin of the most favored nation clause, and some fun customs we see in society. Learn more at CaptainIntegrity.com 

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What’s a referral under the Stark Law and Anti-Kickback Statute (AKS)? In this episode, Captain Integrity Bob Wade dives into the definition. Hear what defines a referral, the 3 specialties that don’t refer, why a referral under the AKS is much broader in comparison with the Stark Law, the history of a famous saying, and the value of a memorable slogan. Learn more at CaptainIntegrity.com 

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In Fiscal Year 2024, the federal government collected $2.9 billion in False Claims Act settlements (FCA). In this episode, Captain Integrity Bob Wade explains what happened. Hear how the qui tam bar is still active, why Stark Law and Fair Market Value issues (FMV) are still very big issues for compliance, how the Department of Justice (DOJ) gives you credit for cooperation & self-reporting, a deep dive into the numbers from 2024, and some fun facts about the settlements. Learn more at CaptainIntegrity.com 

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There are critical steps you need to take if you’re issued a Civil Investigative Demand (CID). In this episode, Captain Integrity Bob Wade explains how it works & what to do. Hear what happens if you fail to respond to a CID, why a legal hold is a must, how to be organized when submitting the documents, the difference between a CID and a subpoena, and some Fig Newtons nostalgia. Learn more at CaptainIntegrity.com

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Hospital-employed physicians can be investors in Ambulatory Surgery Centers (ASCs). In this episode, Captain Integrity Bob Wade wraps up his breakdown of ASCs. Hear what needs to happen for a physician to invest with a hospital in an ASC, why any items or services provided must be consistent with the safe harbors, how the Hospital-Physician ASC works, how many one-third income tests are needed, and a recap of the main takeaways with ASCs. Learn more at CaptainIntegrity.com

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All safe harbors require the one-third income test. In this episode, Captain Integrity Bob Wade continues his breakdown of Ambulatory Surgery Centers (ASCs). Hear how the one-third income test works, when a second one-third test is needed, what the Return on Investment (ROI) needs to be based on, the 4 types of ASCs safe-harbored under the Anti-Kickback Statute (AKS), and how to approach loans. Learn more at CaptainIntegrity.com

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In the case of Ambulatory Surgery Centers (ASCs), the Stark Law does not apply. In this episode, Captain Integrity Bob Wade kicks off his breakdown of ASCs. Hear the pros & cons of ASCs from a patient’s perspective, why the Stark Law does not apply, why ASCs need to be billed under the composite rate, how block booking works for physicians, and the story of Bob’s daughter’s ACL. Learn more at CaptainIntegrity.com 

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 You don’t have to accept what is given to you. In this episode, Captain Integrity Bob Wade dives into Medicaid reimbursement litigation with Knicole Emanuel, Partner at Nelson Mullins. Hear why litigation is an option to fight low Medicaid rates, why you don’t need to accept the reimbursement rates presented, how medical equity works, the David vs. Goliath case Knicole worked on, and some examples in terms of children’s dental needs. Learn more at CaptainIntegrity.com

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The Comp RVU is not the same as the wRVU. In this episode, Captain Integrity Bob Wade continues his discussion on wRVUs & more with Matt BonDurant, Co-Founder & SVP at ProCARE. Hear why Comp RVUs and wRVUs both have complexities, why everyone is handling it differently, the fundamental problem in the industry, examples of modifiers, and who is involved with Comp RVUs. Learn more at CaptainIntegrity.com

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There’s a lot to consider when it comes to RVUs (Relative Value Units). In this episode, Captain Integrity Bob Wade breaks down wRVUs & more with Matt BonDurant, Co-Founder & SVP at ProCARE. Hear what a Comp RVU is, the nuts & bolts of RVUs, why RVUs are so complicated, how to approach benchmark data, and Bob’s story from Philmont Scout Ranch. Learn more at CaptainIntegrity.com

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The 29th Annual Compliance Institute is not to be missed. In this episode, Captain Integrity Bob Wade gives a preview for the conference - which takes place on April 28-May 1, 2025 at the ARIA Resort & Casino in Las Vegas - with Dan Roach, Interim CEO of HCCA (Health Care Compliance Association). Hear what the HCCA does, why the 29th Annual Compliance Institute is a great opportunity to expand your network, the value of in-person conferences on compliance, why compliance education is so important, and the history of Dan & Captain Integrity at the conference. Learn...

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Pooled compensation models are legal. In this episode, Captain Integrity Bob Wade discusses the compliance & legal risks when it comes to pooled compensation models. Hear how to make sure the units going into the pool are Fair Market Value (FMV), how to carefully select pool participants, how the compensation should be divided, Bob’s swimming pool analogy, and some trivia about Two-Face from Batman. Learn more at CaptainIntegrity.com

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With seemingly more & more whistleblowers every day, it’s becoming that much more important to monitor physician compensation arrangements. In this episode, Captain Integrity Bob Wade shares the best practices for oversight of physician compensation arrangements. Hear why it’s all about process, it’s also about documentation, it’s important to obtain good advice from lawyers & consultants, recent examples of whistleblowers, and the perks of having an open door for feedback. Learn more at CaptainIntegrity.com

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When is the violation of the Anti-Kickback Statute a False Claims Act liability? In this episode, Captain Integrity Bob Wade explains the scenario given a recent district court decision. Hear how the “But For” Causation Standard works under the False Claims Act (FCA) and Anti-Kickback Statute (AKS), how the language has changed under the Anti-Kickback Statute, why the issues brought forward were bifurcated, how sales reps played into the decision, and an analogy involving roller coasters & Cedar Point. Learn more at CaptainIntegrity.com 

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Drumroll, please! In this episode, Captain Integrity Bob Wade announces the 2024 “Winners” for Most Egregious US Healthcare Profiteering. Hear why patient care should always be over profits for organizations, why medical necessity is still a primary issue we should be concerned about, why you shouldn’t sell body parts until you get consent, why the award’s named after Martin Shkreli, and Bob’s fandom of “The King of the Countdown” Casey Kasem and the American Top 40 growing up. Learn more at CaptainIntegrity.com

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Not every entity that touches a Designated Health Service is deemed to be a DHS entity as defined under the Stark law. In this episode, Captain Integrity Bob Wade explains why. Hear how a DHS entity is determined, how physicians can still be owners of entities that touch a DHS, what happens if an entity is under arrangement, the 2 major categories of DHS entities, and an example involving Tesla. Learn more at CaptainIntegrity.com

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We have a system that is not geared to ensure we get the healthcare we need. In this Part 2, Captain Integrity Bob Wade continues his discussion of The Big Lie in My Healthcare Bill: Why I Don’t Owe What My Insurer Fails to Pay with Author Frank Lobb. Hear the average error amount in a healthcare bill, how fighting a healthcare bill can impact your credit score, who you should fight in the event of an incorrect healthcare bill, the hidden contract at the core of everything, and what makes Frank’s book...

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Many episodes of Stark Integrity have been focused on healthcare providers. This one is for patients. In this episode, Captain Integrity Bob Wade dives into The Big Lie in My Healthcare Bill: Why I Don’t Owe What My Insurer Fails to Pay with Author Frank Lobb. Hear how Frank became interested in the healthcare billing issue, how healthcare billing works, why the healthcare industry & insurance are so out of control, what to do if your insurer denies paying for your healthcare, and the details of the contracts. Learn more at CaptainIntegrity.com

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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,” and “The 12 Days of Compliance.” Share the poems with your team and learn more at CaptainIntegrity.com

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Want to know what you get for The 12 Days of Compliance? In this special holiday episode, Captain Integrity Bob Wade reflects on 2024 and sings his latest custom Stark Law holiday carol, “The 12 Days of Compliance.” Hear the latest from Bob’s personal life & Nelson Mullins, his favorite things to do in Nashville, the history of “The Twelve Days of Christmas,” fun facts about the birds in the song, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com

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If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck. In this episode, Captain Integrity Bob Wade shares how The Duck Test relates to wRVUs (work Relative Value Units) with Eric Leafgreen, VP of Provider Compensation at Ludi. Hear how to stabilize with oversight, how to embrace simplification through standardization, why you should do an annual check-up, the most overlooked areas that can lead to inaccuracies, and the origin of The Duck Test. Learn more at CaptainIntegrity.com

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During the 1st half of 2024, the Department of Justice’s enforcement activity collected over $1 billion. In this episode, Captain Integrity Bob Wade shares the focus of those DOJ settlements. Hear how the government is still collecting large settlements from providers, how qui tam relators are still bringing these cases to fruition, the importance of having an effective compliance program, the most notable settlements from the 1st half of 2024, and a particular settlement compliance officers will need to “hold their hats for.” Learn more at CaptainIntegrity.com

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Use the data early & often. In this episode, Captain Integrity Bob Wade explores the intersection of data analytics & the False Claims Act (FCA) with Mandy Asgeirsson, Director at BRG (Berkeley Research Group). Hear why it’s really helpful to understand the data available in an FCA investigation, how to be creative in how you use the data to understand the case or allegations against you, why you should use the data proactively instead of just reactively, how data helps to tell the story, and a case where the data analytics shocked Mandy. Learn mo...

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Physician space sharing could be a great strategy - if you follow the rules. In this episode, Captain Integrity Bob Wade discusses physician space sharing as it relates to Stark Law compliance with Mike Vetter, Partner at HMS Valuation Partners. Hear why utilizing space sharing arrangements is a very cost-effective strategy for a healthcare system to expand services to other communities, why it starts with communication, why these arrangements are watched by the CMS (Centers for Medicare & Medicaid Services) and the regulatory language set forth, the biggest pitfalls of these types of arrangement...

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Quality will always matter. In this episode, Captain Integrity Bob Wade discusses quality physician compensation as it relates to the Stark Law with Luis Argueso, Co-Founder & Partner at InHealth Advisors. Hear why quality matters, how to translate that importance of quality into effective incentives for healthcare providers, why there’s a lot of opportunity for innovation in this space, how quality relates to Fair Market Value (FMV), and some “stupid dad jokes” from Bob. Learn more at CaptainIntegrity.com

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This is a fascinating moment in the history of the world. In this episode, Captain Integrity Bob Wade discusses social media and the online world as it relates to healthcare providers and the Stark Law with Mark Weinstein, Author of “Restoring Our Sanity Online” and Speaker of the hit TEDx talk, “The Rise of Surveillance Capitalism.” Hear why Big Tech is driving us mad and we have to get it fixed in a hurry, key lessons we can apply to other industries from Big Ag, Big Energy, and Big Tech, how web platforms can succ...

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What do The Addams Family, 1960s, OIG Agents, Medicare, and Halloween have in common? In this special Halloween episode, Captain Integrity Bob Wade explains the connection as it relates to the Stark Law. Hear all the ‘60s nostalgia you can handle, the history of The Addams Family and creator Charles Addams, the potential for a Captain Integrity TV show, the history of Medicare, and Bob’s special Halloween poem (sung to the tune of The Addams Family), “The Halloween OIG Agents.” Email Bob to get a printed copy of the poem and learn more at...

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Oh no - the dreaded overpayments. In this episode, Captain Integrity Bob Wade explores overpayment notices, mistakes, and the appeal process with Knicole Emanuel, Partner at Nelson Mullins. Hear why tentative notices of overpayments are scary but defensible, why you should know your right to appeal, the potential changes coming that may be in the providers’ best interest, why you should have some legal assistance through this process, and the alphabet soup of acronyms. Learn more at CaptainIntegrity.com

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Is there such a thing as a free lunch in healthcare? In this episode, Captain Integrity Bob Wade gives you the rules, regulations, and requirements as it relates to the Stark Law. Hear why there’s no such thing as a free lunch, what you can do when there are service deficiencies, how to approach providing technology, recent cases that involve free lunches, and the history of free lunches. Learn more at CaptainIntegrity.com

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“Bob, I think we have a big problem on our hands.” In this episode, Captain Integrity Bob Wade continues his discussion of the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear how to act with integrity, know when a case should be bifurcated, revamp your compliance program, why the DOJ got involved, and why the saga continues with this case. Learn more at CaptainIntegrity.com

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And it all started with a Fair Market Value (FMV) defensibility analysis. In this episode, Captain Integrity Bob Wade discusses the facts and insights from the St. Peter's Health Settlement and DOJ (Department of Justice) False Claims Act case with Dr. Tom Weiner. Hear why there should be heightened scrutiny with a Lone Wolf, why you need to pay special attention to a high producer, why most of the services a specialist provides should be in their specialty, the most shocking findings from the case, and Bob’s role in the case. Learn mo...

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Let’s go Back to the Future. In this episode, Captain Integrity Bob Wade “time travels” to all things Chevron deference with Phillip Mullinnix, Partner at Nelson Mullins. Hear why prior court rulings are up for grabs, where to expect more litigation, where to expect lengthy legislation, the history of the Chevron case, and some Back to the Future movie trivia. Learn more at CaptainIntegrity.com

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Emails are evil. In this episode, Captain Integrity Bob Wade explores the new compliance risk of algorithmic pricing with fan-favorite Bart Daniel, Partner at Nelson Mullins. Hear why you should beware of algorithmic pricing, beware of Private Equity (PE), examine the reimbursement rates closely, how to turn your expense department into a revenue department, and why enforcing algorithmic pricing is a top priority. Learn more at CaptainIntegrity.com

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The Improbable Day or Impossible Day is a major compliance issue. In this episode, Captain Integrity Bob Wade chats these scenarios with Kay Hashagen, Senior Consultant with LW Consulting. Hear how to avoid an Improbable Day or Impossible Day scenario, why you should do scheduling audits, why the best defense is a strong offense, the biggest red flags with these scenarios, and a little Tom Cruise and Sherlock Holmes. Learn more at CaptainIntegrity.com

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Data is endlessly impactful in the healthcare space. In this episode, Captain Integrity Bob Wade discusses open payments and compliance findings with Aaron Narva, Co-Founder and CEO of Conflixis. Hear why you shouldn’t underestimate the impact of conflicts in your organization, how your data is available and under scrutiny, why understanding your data can be your secret weapon, some staggering numbers from The Open Payments Report, and how commercial reasonableness (CR) plays into healthcare payments. Learn more at CaptainIntegrity.com

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A referral by a physician of a Designated Health Service (DHS) is the key to opening up the Stark Law City. In this episode, Captain Integrity Bob Wade explains what a DHS is and how they’re categorized. Hear why you should add the CMS (Centers for Medicare & Medicaid Services) website page about the Stark Law to your Favorites, which Stark Law categories are defined by the CPT/HCPCS code, the scenarios where the Stark Law doesn’t apply, what defines a DHS, and the time Captain Integrity got the Key to the City...

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Move it to an asset rather than a liability. In this episode, Captain Integrity Bob Wade talks Corporate Integrity Agreements (CIAs) and Independent Review Organizations (IROs) with Harriett Wall, President and CEO of LW Consulting, Inc. Hear how to avoid CIAs with a strong compliance program, why an IRO should be open to input, how to embrace a CIA for change, whether an OIG Monitor (Office of Inspector General) is a friend or foe, and a Lion King reference from Captain Integrity. Learn more at CaptainIntegrity.com

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Data is a big driver of a lot of cases. In this episode, Captain Integrity Bob Wade breaks down the press release and results from the Criminal National Health Care Fraud Enforcement Action in 2024 with Jillian Willis, Partner at Nelson Mullins. Hear how data analytics remain at the forefront of detecting and prosecuting healthcare fraud, why criminal healthcare fraud enforcement remains a priority for the DOJ (Department of Justice), the importance of having a good culture of compliance, what is considered fraud, and when healthcare fraud is considered a crime. Learn more at...

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Monitoring is a crucial piece of compliance. In this episode, Captain Integrity Bob Wade discusses documenting monitoring efforts with James Rose, Managing Director of SunHawk Consulting. Hear how to provide an annual attestation of compliance, how to build controls and oversight into the business, the difference between auditing and monitoring, where to start when it comes to monitoring, and the biggest monitoring mistakes that occur today. Learn more at CaptainIntegrity.com