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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, and the hotel room example. Learn more at CaptainIntegrity.com
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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 succeed while rejecting horrible practices, how to navigate AI (Artificial Intelligence) as a healthcare provider, and what the early days of social media were like. Learn more at CaptainIntegrity.com
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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 CaptainIntegrity.com
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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 more at CaptainIntegrity.com
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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. Learn more at CaptainIntegrity.com and email Bob to get the slide
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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 CaptainIntegrity.com
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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
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Crises happen all the time. In this episode, Captain Integrity Bob Wade talks next generation root cause analysis with James Rose, Managing Director of SunHawk Consulting. Hear why you should never let a good crisis go to waste, follow up on big near-misses, look at root cause analysis from multiple angles, the background behind root cause analysis, and the biggest mistakes in Six Sigma analysis. Learn more at CaptainIntegrity.com
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What was the Correlation Theory under the Stark Law? In this episode, Captain Integrity Bob Wade explains what it was and how it differs from the Volume or Value Varying Standard and Volume or Value Determination Standard. Hear why the Correlation Theory is dead, when it can still be a valid theory, what to focus on when it comes to Volume or Value, what happened in the Bookwalter case, and some of the most common conspiracy theories and math theories. Learn more at CaptainIntegrity.com
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Compensating Key Opinion Leaders (KOLs) or thought leaders is a little different than regular physician compensation. In this episode, Captain Integrity Bob Wade walks you through how to evaluate KOL compensation. Hear why not every physician is a KOL, why you need to look at the services requested to be performed, how everything boils down to an hourly rate, the importance of the market, and Captain Integrity’s hobby of bird-watching. Learn more at CaptainIntegrity.com
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Are percentage-based compensation arrangements permitted under the Stark Law? In this episode, Captain Integrity Bob Wade explores the answer. Hear the circumstances where percentage-based compensation arrangements are permissible, why they’re prohibited when it comes to office space or equipment rentals, the difference between percentages and percentage points, the most common exceptions where percentage-based compensation arrangements are used, and a poem read by Captain Integrity himself. Learn more at CaptainIntegrity.com
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