Stark Integrity

Send us Fan Mail When analyzing a physician financial arrangement under the Stark Law, you also need to analyze it under the Anti-Kickback Statute (AKS). In this episode, Captain Integrity Bob Wade explains why most of the exceptions under the Stark Law cross-reference the Anti-Kickback Statute. Hear all about the Stark Law & Anti-Kickback Statute dance, the 3 ways to meet the definition of not violating the Anti-Kickback Statute, how to ensure your team understands the intent basis under...

Send us Fan Mail The definition of an “Entity” under the Stark Law includes Managed Care Organizations (MCOs) and the Anti-Markup Rule. In this episode, Captain Integrity Bob Wade details this “Entity” definition under the Stark Law. Hear who the “Entity” usually is, why they expanded the definition, the very narrow exception they came up with, examples of an “Entity” in action, and Bob recite some Miranda Lambert lyrics. Learn more at CaptainIntegrity.com

Send us Fan Mail When a physician doesn’t perform 100% of the services covered by a surgical period, you may have to consider splitting out the global wRVUs. In this episode, Captain Integrity Bob Wade talks global wRVUs and personally performed services as they relate to the Stark Law. Hear the 3 separate categories when a service is covered by a global payment, what happens when a physician didn’t technically perform all the services for a global payment, when it’s possible the physician co...

Send us Fan Mail False Claims Act settlements (FCA): they just keep getting bigger. In this episode, Captain Integrity Bob Wade details the notable False Claims Act settlements for 2025. Hear how qui tam cases continue to represent the largest source of settlements through the Department of Justice (DOJ) and False Claims Act, what it means if the government declines to intervene, why medical necessity continues to be a very large focus, a shocking settlement involving a physician, and fun exa...

Send us Fan Mail There are some uses of the isolated transaction exception that are prohibited under the Stark Law. In this episode, Captain Integrity Bob Wade dives into that isolated transaction exception. Hear why the isolated transaction exception has been expanded, the times when it can be used for service arrangements, how it can be used for settlement of a bona fide dispute, the nuances of the isolated transaction exception, and the history of the famous song, “All by Myself.” Learn mo...