Stark Integrity

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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 

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The larger the country, the longer it takes to get trials approved. In this episode, Captain Integrity Bob Wade explores how compliance works for national & international clinical trials with Julio Martinez-Clark, CEO of bioaccess. Hear how clinical research is global, why some countries approve trials quicker, why patients in developing economies need to have access to these trials, how countries differ with their regulatory requirements, and the hottest topics in compliance. Learn more at CaptainIntegrity.com 

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The best defense is a good offense. In this episode, Captain Integrity Bob Wade discusses the dreaded UPICs (Unified Program Integrity Contractors) with Harriett Wall, President & CEO of LW Consulting. Hear why a UPIC audit is a very serious matter, why you need to organize your team as soon as possible, how to put together a robust compliance plan, who could be the subject of a UPIC audit, and how the appeal process works. Learn more at CaptainIntegrity.com

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Attackers only win when you have no choice left. In this episode, Captain Integrity Bob Wade breaks down the importance of cybersecurity in healthcare & compliance with Matthew Toussain, Founder of Open Security. Hear how to focus on the basics, why you shouldn’t trust anyone, how to know your risk and the enemy, how to stay ahead of cybersecurity attacks, and Matthew’s background in the Air Force. Learn more at CaptainIntegrity.com 

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AI in healthcare is moving at a pace we’ve never seen. In this episode, Captain Integrity Bob Wade explores the fascinating future of AI (Artificial Intelligence) in healthcare with David Norris, Co-Founder & CEO of Affineon Health. Hear why you should embrace AI as a healthcare provider, why this is the most transformative time for healthcare providers, how AI will significantly shift responsibility, how AI can help reduce burnout in the healthcare industry, and the top use cases for AI in healthcare. Learn more at CaptainIntegrity.com 

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Compliance programs matter. In this episode, Captain Integrity Bob Wade discusses the DOJ Civil/Criminal Updated Enforcement Plan with Jillian Willis, Partner at Nelson Mullins. Hear how the DOJ (Department of Justice) is committed to investigating & prosecuting white-collar crime, how the Corporate Whistleblower Awards Pilot Program incentivizes whistleblowers, why compliance programs still matter in each administration, the overlap between criminal & civil protocols, and all the latest updates to the DOJ’s enforcement plan. Learn more at CaptainIntegrity.com 

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Wondering how the One Big Beautiful Bill will impact healthcare if it passes the Senate? In this episode, Captain Integrity Bob Wade shares all you need to know. Hear how a substantial number of Medicaid beneficiaries would lose their status, how rural hospitals could reopen, why the annual increases in the Medicare conversion factor will decrease, the most important takeaways Bob learned while reading the bill, and the biggest differences vs. the current law. Learn more at CaptainIntegrity.com

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Are there ethical considerations in physician compensation arrangements? In this episode, Captain Integrity Bob Wade explains why the answer is a resounding YES. Hear the difference between ethics, compliance, and integrity, why physician compensation models could cause physicians to conduct themselves in an unethical manner, the value society has placed on different occupations, a variety of examples from the healthcare industry, and the client question that sparked this episode idea. Learn more at CaptainIntegrity.com

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Is timely and accurate completion of medical records all about the money? In this episode, Captain Integrity Bob Wade explains why there’s a whole lot more involved. Hear how medical records impact reimbursement and more, how they help establish the physician from a quality standpoint, how they allow for continuity between subsequent providers, the biggest issue when it comes to medical records, and an original poem from Captain Integrity. Learn more at CaptainIntegrity.com 

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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