Stark Integrity
121 episodes - English - Latest episode: 3 days ago - ★★★★★ - 12 ratingsDoes 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
Homepage Apple Podcasts Google Podcasts Overcast Castro Pocket Casts RSS feed
Episodes
Marketing under the Stark Law and Anti-Kickback Statute (AKS)
April 24, 2024 04:00 - 23 minutes - 16.5 MBBillions 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 Exception?
April 17, 2024 03:00 - 18 minutes - 12.7 MBDoes 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
Are wRVUs Physician Compensation's Holy Grail?
April 10, 2024 04:00 - 22 minutes - 15.3 MBUnderstanding 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
Volume or Value Conundrum
April 03, 2024 03:00 - 21 minutes - 15 MBThe 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
Part 2: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions
March 27, 2024 04:00 - 21 minutes - 14.9 MBTelehealth 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
Part 1: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions
March 20, 2024 05:00 - 19 minutes - 13.4 MBTelehealth 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 a...
Importance of Documentation in Physician Financial Arrangements
March 13, 2024 03:00 - 19 minutes - 13.6 MBMake 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. ...
DOJ 2023 Fiscal Year False Claims Act Settlements
March 06, 2024 04:00 - 23 minutes - 16.1 MBThe 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 & Billi...
The Connection (and Disconnect) between Commercial Reasonableness and Fair Market Value
February 28, 2024 05:00 - 22 minutes - 15.7 MBFair 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
Stark Law and Substance Abuse and Addiction
February 21, 2024 04:00 - 24 minutes - 17.1 MBUnder 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
Fair Market Value under New Stark Law Regulations: A Discussion with Tim Smith from TS Healthcare Consulting
February 14, 2024 05:00 - 37 minutes - 25.6 MBCommercial 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 Regulation...
Employing Hospital-Based Specialists…Now What? A Discussion with Joe Aguilar and Natalie Bell from HMS Valuation Partners
February 07, 2024 04:00 - 26 minutes - 18.2 MBIf 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
Part 3: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP
January 31, 2024 05:00 - 32 minutes - 22.5 MBLook 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,...
Part 2: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP
January 24, 2024 04:00 - 31 minutes - 21.6 MBYou 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 Janu...
Part 1: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP
January 17, 2024 05:00 - 27 minutes - 19.1 MBA 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 settleme...
Crisis Communication Management in Healthcare: A Discussion with Eileen Wixted from Wixted & Co.
January 10, 2024 05:00 - 32 minutes - 22.7 MBIf 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
Part 2: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower
January 03, 2024 05:00 - 27 minutes - 19.2 MBYou’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 ...
Part 1: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower
December 27, 2023 03:00 - 31 minutes - 21.6 MBBe ethical. In this special episode, Captain Integrity Bob Wade breaks down 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 her experiences and challenges being a whistleblower, how she lost her job but gained respect, what to do if you see something unethical, how the structure at Facebook (now Meta) worked, and what happens when you put things in writing. Lear...
Part 2: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health
December 20, 2023 04:00 - 30 minutes - 20.8 MBBe careful what you put in writing. In this special episode, Captain Integrity Bob Wade discusses the recent General Compliance Program Guidance (GCPG) issued by the OIG (Office of Inspector General) with Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 2 of a 2-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on November 16, 2023. Hear the questions and issues the OIG has...
Part 1: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health
December 13, 2023 10:00 - 26 minutes - 18.5 MBMitigate your risk. In this special episode, Captain Integrity Bob Wade discusses the recent General Compliance Program Guidance (GCPG) issued by the OIG (Office of Inspector General) with Alex Krouse, Associate General Counsel - Provider Arrangements at Parkview Health. This is Part 1 of a 2-part episode, originally recorded as a webinar for the American Association of Provider Compensation Professionals (AAPCP) on November 16, 2023. Hear the history of the OIG issuing guidance, why you nee...
Stark Law Holiday Poems: “'Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” and “Jolly OIG Agent”
December 11, 2023 01:00 - 8 minutes - 6.1 MBHear Captain Integrity Bob Wade read his original Stark Law holiday poems, “‘Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” and “Jolly OIG Agent.” Share the poems with your team and learn more at CaptainIntegrity.com
Jolly OIG Agent: 2023 Stark Integrity Holiday Poem
December 06, 2023 05:00 - 13 minutes - 9.33 MBThank you, listeners, for making this 100th episode of Stark Integrity happen. In this special milestone and holiday episode, Captain Integrity Bob Wade reflects on 2023 and reads his latest custom Stark Law holiday poem, “Jolly OIG Agent.” Hear what Bob is grateful for in 2023, his latest thoughts on the Stark Law, the history of a certain controversial holiday poem, what to expect next from Stark Integrity, and the Stark Law holiday poem you can share with your team. Learn more at CaptainI...
Fixed Asset Valuations: A Discussion with Mike Vetter with HMS Valuation Partners
November 29, 2023 05:00 - 28 minutes - 19.4 MBA chair is more than a chair. In this episode, Captain Integrity Bob Wade dives into fixed asset valuations under the Stark Law with Mike Vetter, Partner at HMS Valuation Partners. Hear why valuations in healthcare have additional regulatory guidelines and laws to follow, the devil is in the details, using a certified appraiser with healthcare experience can help keep you compliant, the weirdest fixed assets Mike has had to value, and what The Wizard of Oz has to do with fixed asset valuatio...
Recruitment and Physician Needs Assessment (PNA): A Discussion with Stephen Ross and Justin Chamblee from Coker Group
November 22, 2023 05:00 - 27 minutes - 19.2 MBThere’s going to be more and more competition in the healthcare space. In this episode, Captain Integrity Bob Wade discusses recruitment and the Physician Needs Assessment (PNA) as it relates to the Stark Law with Coker Group VP Stephen Ross and EVP Justin Chamblee. Hear why there will be a continued strain on organizations to provide access to high-quality healthcare, why you need to use and regularly update a PNA in order to confirm Commercial Reasonableness (CR), how the value of the PNA ...
Medical Directors: Can't Live With Them, Can't Live Without Them
November 15, 2023 04:00 - 24 minutes - 16.7 MBThere are a multitude of compliance issues related to medical directors. In this episode, Captain Integrity Bob Wade explains why there’s a struggle, yet they’re so important. Hear why you need to evaluate the commercial reasonableness (CR) of the medical director administrative arrangement, how to determine the hourly rate using clinical benchmark data, how to verify the services and hours are reasonable when the time records are available, famous Stark Law cases involving medical directors...
Stark Law Timing: 1 Year, 2 Years, 5 Years, and More Timing Limitations
November 08, 2023 04:00 - 22 minutes - 15.3 MBWhy are there timing requirements under the Stark Law? In this episode, Captain Integrity Bob Wade explores the background and details of these limitations. Hear why the 1-year term is a standalone provision under the exception, when the calendar year vs. a rolling period applies, why you should be careful about the multiple use of various exceptions, how timing limitations are determined, and an original poem for this episode. Learn more at CaptainIntegrity.com
Hospital-Based Financial Arrangements: A Discussion with Joe Aguilar with HMS Valuation Partners
November 01, 2023 04:00 - 32 minutes - 22.2 MBThere are a ton of considerations when it comes to hospital-based financial arrangements under the Stark Law. In this episode, Captain Integrity Bob Wade goes into the numbers and details with Joe Aguilar, Partner at HMS Valuation Partners. Hear why it’s important to include all aspects of revenue when determining Fair Market Value (FMV), why you need to understand the Full-Time Equivalents (FTEs), why you shouldn’t be afraid to start considering building the service line in house, why the d...
Master List Requirement under the Stark Law Explained
October 25, 2023 03:00 - 23 minutes - 16.4 MBA master list reference is sometimes necessary under the Stark Law. In this episode - suggested by a Stark Integrity listener - Captain Integrity Bob Wade explains when and why that’s the case. Hear why creating a master list is just good practice, why it’s a legal requirement to cross-reference it, why you need to dedicate resources to maintain a master list, some interesting numbers tied to master lists, and what The Sound of Music has to do with them. Learn more at CaptainIntegrity.com
Stark Law Settlements under the Self-Referral Disclosure Protocol (SRDP): How Long and How Much?
October 18, 2023 04:00 - 20 minutes - 14.2 MBWhen do you need to enter into the Self-Referral Disclosure Protocol (SRDP)? In this episode, Captain Integrity Bob Wade talks the notable settlements and timing under the SRDP. Hear how the CMS (Centers for Medicare and Medicaid Services) is investing greater resources to review and settle these Stark Law violations, why it can be a long process, why it’s advantageous to enter the protocol process, how to do so, and the record-setting numbers tied to the SRDP. Learn more at CaptainIntegrity...
Stark Law Compliance Mash
October 11, 2023 04:00 - 3 minutes - 2.28 MBHear Captain Integrity Bob Wade perform his original Stark Law Halloween song, “Compliance Mash.” Share the song with your team and learn more at CaptainIntegrity.com
History of Fair Market Value and Wade's Personal Impact on FMV Standard
October 04, 2023 05:00 - 25 minutes - 17.3 MBLet’s take a ride through history regarding Fair Market Value (FMV). In this episode, Captain Integrity Bob Wade dives into the key points along the FMV timeline. Hear why it really started in 1991, it’s been guided by key cases and settlements, the definition has continued to be refined up through today, the most important regulations over time, and what the year 1965 has to do with FMV. Learn more at CaptainIntegrity.com
Academic Medical Centers Exception: What Is It and How Can It Be Used?
September 27, 2023 03:00 - 23 minutes - 15.9 MBThe Stark Law has its own exception related to Academic Medical Centers. In this episode, Captain Integrity Bob Wade explores its application and alternatives. Hear the definition of Academic Medical Centers, where there’s some leeway, why you might not need to meet the exception, direct vs. indirect compensation arrangements, and how research grants impact things. Learn more at CaptainIntegrity.com
Operational Challenges in Physician Financial Arrangements: Who Is Driving the Bus?
September 20, 2023 02:00 - 22 minutes - 15.4 MBIt’s very important to monitor provider financial arrangements. In this episode, Captain Integrity Bob Wade dives into the operational challenges that arise. Hear why the biggest source of compliance issues is through the operation of that contract, you can trust but verify, the importance of knowing who your bus drivers are, some examples of the wheels falling off, and an Urban Dictionary shoutout. Learn more at CaptainIntegrity.com
False Claims Act 2023 Mid-Year Review
September 13, 2023 03:00 - 26 minutes - 18.6 MBThere have been some surprising and some not-so-surprising settlements under the False Claims Act (FCA) so far in 2023. In this episode, Captain Integrity Bob Wade details the most interesting decisions. Hear why the qui tam bar is still extremely active, there appears to be a great focus on the specialty of ophthalmology, Fair Market Value (FMV) and Stark Law issues are still high on the list, the most notable cases, and one that has a shock factor. Learn more at CaptainIntegrity.com
CARES Act Fraud: Discussion with Bart Daniel from Nelson Mullins
August 30, 2023 01:00 - 27 minutes - 18.6 MBThere’s a lot to unpack from all that happened in 2020. In this episode, Captain Integrity Bob Wade dives into the fallout from the CARES Act with Bart Daniel, Partner at Nelson Mullins. Hear what the CARES Act is, the landscape of fraud relating to the CARES Act, why the PPP (Paycheck Protection Program) was abused so commonly, how the government is pursuing those who abused these programs, and who the whistleblower typically is. Learn more at CaptainIntegrity.com
Call Arrangements in the Healthcare Industry: Discussion with Ashley Graver from Coker Group
August 16, 2023 01:00 - 26 minutes - 18.4 MBCall arrangements are a hot topic for many entities in the healthcare space. In this episode, Captain Integrity Bob Wade discusses the details with Ashley Graver, Vice President of Coker Group. Hear why organizations should carefully consider the need for each call coverage arrangement, organizations should approach payment for calls in an equitable manner, why you shouldn’t set it and forget it, the type of market data available, and a classic “beeper” reference. Learn more at CaptainIntegr...
Civil and Criminal Investigations in the Healthcare Industry: Discussion with Bart Daniel from Nelson Mullins
August 02, 2023 03:00 - 25 minutes - 17.5 MBCivil and criminal investigations have become a huge focus in the healthcare industry. In this episode, Captain Integrity Bob Wade discusses why that’s the case with Bart Daniel, Partner at Nelson Mullins. Hear when you should retain experienced white collar healthcare counsel immediately, how to determine the nature and scope of the investigation, why you should cease any borderline conduct immediately, how an investigation begins, and “The Parade of Horribles.” Learn more at CaptainIntegri...
Fair Market Value Analysis Mistakes
July 26, 2023 02:00 - 20 minutes - 13.8 MBThere are several mistakes that can be made when conducting a Fair Market Value (FMV) review. In this episode, Captain Integrity Bob Wade dives into these mistakes and how to prevent them. Hear why FMV opinions are qualified, you should focus on personally performed productivity, how to make sure you understand the full-time equivalency (FTE) of the physician you’re reviewing, the “Dirty Dozen” of FMV analysis mistakes, and how wRVUs fit into the mix. Learn more at CaptainIntegrity.com
Time-Share Lease Arrangements in Healthcare: Conversation with Ron Young from The Advisory Group
July 19, 2023 00:00 - 26 minutes - 18.2 MBHow do time-share lease arrangements work in the healthcare world? In this episode, Captain Integrity Bob Wade dives into the details with Ron Young, President and Owner of The Advisory Group. Hear why consistency in your methodology is critical, the monitoring of the space needs to be documented, when to think like a patient, why a hospital or medical provider would time-share real estate, and the hotel room analogy. Learn more at CaptainIntegrity.com
Fair Market Value, Commercial Reasonableness, and Remuneration: Does FMV Cover All Sins?
July 12, 2023 02:00 - 22 minutes - 15.3 MBThere is a legal storm brewing over the definition of remuneration. In this episode, Captain Integrity Bob Wade breaks down all the factors under the Stark Law. Hear why it needs to meet a safe harbor, it needs to meet Fair Market Value (FMV) and Commercial Reasonableness (CR), why you shouldn’t make the connection between the financial arrangement and the inducement for referrals, notable cases to discuss, and how the transfer of value plays into things. Learn more at CaptainIntegrity.com
False Claims Act: Supreme Court Holds Knowledge Is Subjective Not Objective: Discussion with Bart Daniel from Nelson Mullins
June 14, 2023 02:00 - 21 minutes - 14.7 MBClear, concise, easily understood. In this episode, Captain Integrity Bob Wade discusses the Supreme Court’s ruling on the False Claims Act (FCA) with Bart Daniel, Partner at Nelson Mullins. Hear why no after-the-fact justification can be used to knowingly file a false claim, the subjective standard is the standard, the court made it clear the False Claims Act is rooted in common law fraud, the 3 definitions of knowledge under the False Claims Act, and what drew a Paul Harvey reference from ...
Part 2: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting
June 07, 2023 02:00 - 19 minutes - 13.3 MBBig changes are coming. In this episode, Captain Integrity Bob Wade continues his discussion of split/shared billing for Advanced Practice Providers (APPs) with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting. Hear how the crediting of wRVUs will be affected, the impact the change will have on measures of productivity, why you should consider changes to provider compensation plans, what it means for compensation for NPPs, and how Fair Market Value (FMV) plays into things. L...
Part 1: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting
May 31, 2023 03:00 - 27 minutes - 18.8 MBIt’s going to get confusing. In this episode, Captain Integrity Bob Wade talks split/shared billing for Advanced Practice Providers (APPs) with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting. Hear when the new guidelines go into effect, why the documentation must be substantive, how to correctly identify the date of service, the difference between APPs and NPPs, and what this all means for split/shared visits. Learn more at CaptainIntegrity.com
False Claims Act (FCA): Is Knowledge Objective or Subjective
May 24, 2023 04:00 - 20 minutes - 13.8 MBIs the knowledge requirement under the False Claims Act (FCA) objective or subjective? In this episode, Captain Integrity Bob Wade dives into the murky waters. Hear why the fines and penalties if the FCA applies are huge, murky regulations could be a defense under the FCA, why you should continue to operate as if the subjective factors would apply, the highlights from recent FCA cases, and the origin of the FCA. Learn more at CaptainIntegrity.com
Advanced Practice Providers (APPs): Compliance Risks and Safeguards
May 17, 2023 03:00 - 21 minutes - 14.9 MBIncorporating Advanced Practice Providers (APPs) has many benefits and risks. In this episode, Captain Integrity Bob Wade lays out those compliance risks and safeguards. Hear the 4 components of the quadruple aim, why you need documentation for incident-to and split/shared visits, how to handle credit given to any physician for the wRVUs performed by the APP, who’s considered an APP, and the discussion point in which Bob might be stepping into quicksand. Learn more at CaptainIntegrity.com
Eliminating Kickbacks in Recovery Act (EKRA): Comparison with the AKS
May 03, 2023 02:00 - 21 minutes - 14.9 MBThe Eliminating Kickbacks in Recovery Act (EKRA) is a huge statute. In this episode, Captain Integrity Bob Wade discusses the similarities and differences between EKRA and the Anti-Kickback Statute (AKS). Hear why EKRA applies to private payers, there are broader applications under EKRA as opposed to the AKS, how EKRA applies generally to clinical laboratories, the origin of EKRA, and “liquid gold” in the recovery world. Learn more at CaptainIntegrity.com
Part 2: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel
April 26, 2023 03:00 - 23 minutes - 16.3 MBThe Tuomey case is a pinnacle case for healthcare regulatory attorneys. In this episode, Captain Integrity Bob Wade continues his Tuomey case discussion with Bart Daniel, Partner at Nelson Mullins. Hear why you need to take complaints from employees seriously, why you shouldn’t seek a 2nd opinion on Fair Market Value (FMV) and Commercial Reasonableness (CR), how to structure a model that is compliant and defensible, why the government used the Tuomey case as a poster child, and what issues t...
Part 1: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel
April 19, 2023 03:00 - 46 minutes - 32.1 MBThere’s a lot we can learn from the landmark Tuomey case in the healthcare industry. In this episode, Captain Integrity Bob Wade discusses the Stark Law and legal learnings with someone who was involved firsthand in the case: Bart Daniel, Partner at Nelson Mullins. Hear why you shouldn’t dig the hole deeper, why you should take 1 appraisal and stick with it, how to settle a False Claims Act case, why the Tuomey case went down the way it did, and why it ended up being a way bigger case than i...
Stark Law and Anti-Kickback Issues with Healthcare Transactions
April 12, 2023 03:00 - 18 minutes - 12.7 MBHealthcare transactions are different from ordinary transactions. In this episode, Captain Integrity Bob Wade discusses the issues we should be focusing on in the healthcare space. Hear how to ensure the arrangement is Fair Market Value (FMV), why you should purchase assets, when not to assume liability for physicians, the biggest transactional issues in the healthcare space, and when to figure out if the Stark Law applies. Learn more at CaptainIntegrity.com
Unique Trends and Compliance Issues with Value-Based Reimbursement Arrangements: A Discussion with Christine Worthen of Nelson Mullins
March 22, 2023 03:00 - 18 minutes - 12.8 MBThere’s been a fascinating shift to value-based reimbursement arrangements from those based on production. In this episode, Captain Integrity Bob Wade discusses trends and issues in that space with Christine Worthen, Partner at Nelson Mullins. Hear why you should consider your strategic planning for the glide path to risk, look at the regulatory addendum and negotiate it, always have providers at the table, opportunities within deferred compensation, and how you can mitigate the risk of take...