Stark Integrity

To per-click or not to per-click? That is the question. In this episode, Captain Integrity Bob Wade breaks down all things per-click arrangements under the Stark Law. Hear why per-click arrangements are permissible under limited circumstances, how it works with lessors and lessees, what you can bundle together, the most common misconceptions about per-click arrangements, and everyt

It’s an evolving industry. In this episode, Captain Integrity Bob Wade breaks down compensation learnings from the AAPCP (American Association of Provider Compensation Professionals) Annual Conference with Chris Fete, Partner at Pinnacle Healthcare Consulting (PHC). Hear why the growth and involvement of AAPCP is important for the industry, why the AAPCP credential is a good thin

How do you identify covert retaliation? In this episode, Captain Integrity Bob Wade reveals 8 categories of covert retaliation as they relate to the Stark Law. Hear the 2 broad categories of retaliation, how the anti-retaliation provisions under the False Claims Act (FCA) are separate causes of action an individual can bring against entity and individuals, why covert retaliation is

Billions of dollars are spent on marketing in the healthcare sector each year. In this episode, Captain Integrity Bob Wade explains why such marketing can cause issues under the Stark Law and Anti-Kickback Statute (AKS). Hear why marketing between referral sources is not illegal, you need to look at the development and placement of the advertisement, Fair Market Value (FMV) is king

Does the Stark Law have a de minimis compensation exception? In this episode, Captain Integrity Bob Wade explores whether one exists. Hear what a de minimis compensation exception means, why the compensation must still be Fair Market Value (FMV) and Commercially Reasonable (CR), why you don’t need to have a written agreement after the fact, examples from the world of the Stark La

Understanding a wRVU (work Relative Value Unit) might feel like searching for the Holy Grail. In this episode, Captain Integrity Bob Wade explains what a wRVU is. Hear why you need to understand what a wRVU is, why work effort is a component, how to avoid the pitfalls with wRVUs, some of the many acronyms in the healthcare industry, and a classic Monty Python story. Learn more at C

The Volume or Value Restriction under the Stark Law is a conundrum. In this episode, Captain Integrity Bob Wade breaks down how to approach compensation under the Stark Law. Hear why aggregate compensation can vary, why you can use the same analysis under the safe harbors under the Anti-Kickback Statute (AKS), why you should keep your compensation determination process separate, ho

Telehealth is here to stay. In this episode, Captain Integrity Bob Wade continues his discussion on telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how to think through which encounters would benefit from telehealth, why consent is so important, why prevention is key, the guidance on coding and b

Telehealth should be a service that is used to diagnose and treat a patient. In this episode, Captain Integrity Bob Wade talks telehealth and its impact on the healthcare industry with Christine Hall, CEO and Senior Consultant at Stirling Global Solutions. Hear how telehealth works, new legislation that affects telehealth, compliance risks associated with telehealth, how Christine�

Make sure documentation related to physician financial arrangements helps you, not hurts you. In this episode, Captain Integrity Bob Wade shares how this documentation can work to your advantage. Hear why training is critical, why you should look at your documentation through the eyes of the Department of Justice (DOJ), Officer of Inspector General (OIG), or a qui tam relator, how