Stark Integrity

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Real estate is a major Stark Law and compliance issue. In this episode, Captain Integrity Bob Wade shares the vast real estate complexities that can arise under the Stark Law. Hear how often you should obtain a market survey, how to compare leases, what the lease arrangement must say, how to do a survey, and what Bob would do in a reality show with compliance officers. Learn more at CaptainIntegrity.com and email Bob for his real estate complexity checklist

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A Fair Market Value Defensibility Analysis takes a compensation review one step further than a FMV Review under the Stark Law. In this episode, Captain Integrity Bob Wade points out the key differences between the two. Hear why there is a legal difference between a simple FMV review and a FMV Defensibility Analysis, whether commercial reasonableness is in play, how much to consider the subjective and business judgment factors, whether you can ask the government to give you an answer, and the FMV range. Learn more at CaptainIntegrity.com and email Bob for his checklist

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Stark Law compliance begins with having the right people at the table motivated for the right business or medical need. In this episode, Captain Integrity Bob Wade breaks down 3 scenarios involving C-suite players and the Stark Law. Hear why legal and compliance teams should be part of the deal-making process, legal counsel should not just “paper” the deal, how to carefully consider what is motivating the deal, whether the services performed matter, and how to handle independent contractors. Learn more at CaptainIntegrity.com

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If you think you have a Stark Law violation, take a step back, a deep breath, and follow Captain Integrity’s advice. In this episode, Captain Integrity Bob Wade shares what to do if you think your organization has a Stark Law violation. Hear what to do first, how to carefully consider all exceptions, consider all potential compliant resolutions, the 3 components for Stark Law to be implicated, and 3 excepted specialties. Learn more at CaptainIntegrity.com and email Bob for his 2 CliffsNotes slides

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Physician Employment is a great integration strategy, but legal and compliance risks need to be managed. In this episode, Captain Integrity Bob Wade details the ins and outs of Physician Employment under Stark Law and shares real-life examples. Hear why there’s more flexibility compared to other aspects of the Stark Law, compensation must be based on personally performed services, you need to keep the focus on total cash compensation, when things could get problematic, and why it can be a very good tool. Learn more at CaptainIntegrity.com

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The non-monetary compensation exception is so broad and complicated, it deserves a second episode. In this episode, Captain Integrity Bob Wade shares more real-life examples of the non-monetary compensation exception. Hear why you need to track non-monetary compensation, it helps to allocate a dollar amount for marketing trinkets, business dinners are considered to be compensation for the physician, examples from hospital holiday parties, and why the location of the meeting matters. Learn more at CaptainIntegrity.com

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The dreaded non-monetary compensation exception can get pretty tricky. In this episode, Captain Integrity Bob Wade discusses what items meet the non-monetary compensation exception under the Stark Law, including real-life examples. Hear why the definition of remuneration plays a key part, it’s essential to track non-monetary compensation on an annual basis, how to track the value of a unified gift, the “cousin” exception, and the most common examples during the holiday season. Learn more at CaptainIntegrity.com

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Hear Captain Integrity Bob Wade read his original Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Share the poem with your team and learn more at CaptainIntegrity.com

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It’s important to understand the differences between ownership and compensation arrangements - both direct and indirect. In this episode, Captain Integrity Bob Wade breaks down the differences between each under the Stark Law, and where various exceptions apply. Hear how to draw out the various arrangements to determine what’s what, look at downward ownership in the chain, the definition of compensation, the Stand in the Shoes concept, and the impact of stock ownership under the Stark Law. Learn more at CaptainIntegrity.com

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It’s important to make compliance relevant, focused on ethical behavior, and fun. In this special holiday episode, Captain Integrity Bob Wade reveals how he got into Stark Law compliance in the first place and reads a custom Stark Law holiday poem, “‘Twas The Night Before The Subpoena.” Hear what Bob represents clients on, how to make compliance fun, celebrate the people you work with, how Bob created Captain Integrity, and the Stark Law holiday poem you can share with your team. Learn more at CaptainIntegrity.com