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All Episodes

Stark Integrity — 218 episodes

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Title
1

Part 1: Holistic Audits: Synchronizing Professional & Facility Reviews: A Discussion with Kelly Loya & Bruce Truitt, Pinnacle Enterprise

2

Effective Compliance Programs Return 2x-5x Return on Investment (ROI)

3

Anti-Kickback Compliance and Stark Exceptions: “I’ll Get You My Pretty and Your Little Dog Too”

4

“Entity” Definition Expansion (MCOs) and Exclusion (Anti-Markup): Is a House a Home?

5

Global wRVUs and “Personally Performed Services”: Around the World in 80 Days

6

False Claims Act Settlements for 2025 (FCA)

7

Isolated Transaction Exception under the Stark Law: “All by Myself”

8

Part 2: Cybersecurity and the False Claims Act (FCA), Two Great Tastes that Taste Great Together: A Discussion with Bart Daniel, Partner, Nelson Mullins

9

Part 1: Cybersecurity and the False Claims Act (FCA), Two Great Tastes that Taste Great Together: A Discussion with Bart Daniel, Partner, Nelson Mullins

10

What Are Not Ownership Interests under the Stark Law: The Devil Is in the Details

11

Loans Are Ownership Interests under the Stark Law: When in Rome, Do as the Romans Do

12

Part 2: Artificial Intelligence (AI) & Fair Market Value (FMV) under Stark Law & Anti-Kickback Statute (AKS): A Discussion with Chris David, Managing Partner, HealthValue Group

13

Part 1: Artificial Intelligence (AI) & Fair Market Value (FMV) under Stark Law & Anti-Kickback Statute (AKS): A Discussion with Chris David, Managing Partner, HealthValue Group

14

FQHCs, AKS, Stark Law, and “Pulling Together”

15

Expert Witness Selection, Preparing, and Utilization: A Discussion with White Collar Crime Attorney Sean McKenna

16

Part 3: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren Skyles

17

Part 2: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren Skyles

18

Part 1: Artificial Intelligence (AI) in Healthcare Law & Compliance: A Discussion with Nelson Mullins Partners Bob Coffield & Darren Skyles

19

Compliance Program Effectiveness: The 8th Element of an Effective Compliance Program

20

How to Deliver Bad News: A Conversation with Mimi Bliss, Leadership Communications Consultant with Bliss Communications

21

Health Law and Compliance Christmas Specials 2021 - 2025

22

2025 Christmas Episode with “Santa Baby” Parody

23

From Probe Audit to False Claims Act Liability (FCA): How Did We Get Here?

24

What? I Married the Stark Law?

25

AI Use and Guardrails in Healthcare: A Discussion with Natalie Ramello, VP, Chief Compliance & Audit Officer, UT Southwestern Medical Center

26

“Personally Performed” Services and Autonomous Vehicles

27

TPE (Targeted Probe and Educate) Audits: A Conversation with Kay Hashagen, Senior Consultant with LW Consulting

28

Compliance Advisory Support and Why It Brings Value: A Conversation with Sheila Limmroth, Executive Consultant and Compliance Officer at Pinnacle Healthcare

29

Captain Integrity and the Curse of Stark Hallow and Halloween Costumes through the Years

30

Transparency, Action, and The 2025 Open Payments Report: A Discussion with Aaron Narva, CEO of Conflixis

31

Part 3: Non-Monetary Compensation and Medical Staff Incidental Benefits: A Discussion with the American Association of Physician Liaisons (AAPL)

32

Part 2: Non-Monetary Compensation and Medical Staff Incidental Benefits: A Discussion with the American Association of Physician Liaisons (AAPL)

33

Part 1: Non-Monetary Compensation and Medical Staff Incidental Benefits: A Discussion with the American Association of Physician Liaisons (AAPL)

34

Reckless Disregard/Deliberate Ignorance Under the False Claims Act: “You Can’t Handle the Truth”!

35

Probe to Statistically Valid Reviews: When to “Keep on Digging”

36

wRVUs and Modifier 25: Did the Physician "Go the Extra Mile"?

37

Don’t Shoot the Messenger

38

Compliance Officer: You Are Not an Independent Auditor

39

2025 Healthcare Enforcement Priorities: A Discussion with Brook Andrews, Partner at Nelson Mullins

40

Medical Staff Funds & The Stark Law

41

Do You Know Where Your Physicians Are? Underperformance Can Cause Financial Arrangements to Exceed Fair Market Value (FMV)

42

DOJ and HHS New False Claims Act Working Group Targeting Healthcare Fraud: A Discussion with Knicole Emanuel, Partner at Nelson Mullins

43

Clinical Trials National & International Compliance: A Discussion with Julio Martinez-Clark, CEO of bioaccess

44

UPICs: What They Are and How to Avoid: A Discussion with Harriett Wall, President & CEO of LW Consulting

45

Cybersecurity Risk Management in Healthcare & Compliance: A Discussion with Matthew Toussain, Founder of Open Security

46

AI's Use in Alleviating Physician Burdens: A Discussion with David Norris, Co-Founder & CEO of Affineon Health

47

DOJ Civil/Criminal Updated Enforcement Plan: A Discussion with Jillian Willis, Partner at Nelson Mullins

48

One Big Beautiful Bill’s Impact on Healthcare

49

Ethics and Compliance and Integrity in Physician Compensation Arrangements

50

Medical Records: Why Timely and Accurate Completion Is Beneficial to Physicians

51

Compliance Officers in Las Vegas: HCCA’s 29th Annual Compliance Institute

52

Usual and Customary Charges with Medicare and Most Favored Nation Clauses

53

Referrals “Get the Ball Rolling”

54

2024 False Claims Act Settlements and Judgments: $2.9B in Fiscal Year

55

Civil Investigative Demands (CID): Critical Steps for Responding

56

Part 3: Ambulatory Surgery Centers (ASCs): The Nuts and Bolts and Legal Requirements

57

Part 2: Ambulatory Surgery Centers (ASCs): The Nuts and Bolts and Legal Requirements

58

Part 1: Ambulatory Surgery Centers (ASCs): The Nuts and Bolts and Legal Requirements

59

Medicaid Reimbursement Litigation Is Possible: A Discussion with Knicole Emanuel, Partner at Nelson Mullins

60

Part 2: Why Is Sanitizing wRVUs Important (Comp RVU) vs. Reported wRVUs: A Discussion with Matt BonDurant, SVP at ProCARE

61

Part 1: Why Is Sanitizing wRVUs Important (Comp RVU) vs. Reported wRVUs: A Discussion with Matt BonDurant, SVP at ProCARE

62

Compliance Education and the 29th Annual Compliance Institute (Las Vegas): An Interview with Dan Roach, HCCA's Interim CEO

63

Pooled Compensation: Creation, Distribution, and the Probability Factor for Personally Performed Services

64

Best Practice Oversight of Physician Compensation Arrangements

65

Roller Coasters, Sales Representative Comp, and the “But For” Causation Standard under the False Claims Act and Anti-Kickback Statute

66

2024 “Winners” for Most Egregious US Healthcare Profiteering

67

DHS Entity Defined and Tesla Example

68

Part 2: The Big Lie in My Healthcare Bill: A Discussion with Author Frank Lobb

69

Part 1: The Big Lie in My Healthcare Bill: A Discussion with Author Frank Lobb

70

Stark Law Holiday Poems: 'Twas the Night before the Subpoena, Rudy the Seasoned Compliance Officer, Jolly OIG Agent, and The 12 Days of Compliance

71

The 12 Days of Compliance: 2024 Holiday Special

72

The Duck Test & wRVUs: A Discussion with Eric Leafgreen, VP of Provider Compensation at Ludi

73

DOJ 6-Month Settlements (2024): The Issues, the Relators, and the Amounts

74

Data Analytics & the False Claims Act: A Discussion with Mandy Asgeirsson, Director at BRG

75

Physician Space Sharing & Stark Law Compliance: A Discussion with Mike Vetter, Partner at HMS Valuation Partners

76

Quality Physician Compensation: A Discussion with Luis Argueso, Partner at InHealth Advisors

77

Restoring Our Sanity Online: A Discussion with Author Mark Weinstein

78

The Addams Family, 1960s, OIG Agents, Medicare, and Halloween

79

Overpayment Notices, Mistakes, and Appeal Process: A Conversation with Knicole Emanuel, Partner at Nelson Mullins

80

Free Lunches and Technology to Patients: What Is Permissible under CMP, AKS, and the Stark Law

81

Part 2: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom Weiner

82

Part 1: Learnings and Insights from the St. Peter's Health Settlement and DOJ False Claims Act Case with Dr. Tom Weiner

83

Back to the Future with Chevron Deference: A Discussion with Phillip Mullinnix, Partner at Nelson Mullins

84

Algorithmic Pricing, a New Compliance Risk: A Discussion with Bart Daniel, Partner at Nelson Mullins

85

Mission Improbable: A Discussion with Kay Hashagen, Senior Consultant with LW Consulting, about the Impossible Day

86

Open Payments: A Conversation with Aaron Narva, CEO of Conflixis, Regarding Compliance Findings and Nature of Reported Payments

87

Designated Health Services (DHS): The Key to the Stark Law City

88

Corporate Integrity Agreements (CIAs) and Independent Review Organizations (IROs): A Discussion with Harriett Wall, CEO of LW Consulting, Inc.

89

Criminal National Health Care Fraud Enforcement Action 2024: A Discussion with Jillian Willis, Partner, Nelson Mullins

90

Documenting Monitoring Efforts: A Discussion with James Rose from SunHawk Consulting

91

Next Generation Root Cause Analysis: A Discussion with James Rose from SunHawk Consulting

92

Correlation Theory vs. Volume or Value Varying Standard vs. Volume or Value Determination Standard

93

A Rare Bird: Fair Market Value for Key Opinion Leaders

94

Percentage Arrangements under the Stark Law

95

To Per-Click or Not to Per-Click, That Is the Question

96

Compensation Learnings from AAPCP Annual Conference: Discussion with Chris Fete, Partner, Pinnacle Healthcare Consulting

97

How to Identify Covert Retaliation

98

Marketing under the Stark Law and Anti-Kickback Statute (AKS)

99

Does the Stark Law Have a De Minimis Exception?

100

Are wRVUs Physician Compensation's Holy Grail?

101

Volume or Value Conundrum

102

Part 2: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions

103

Part 1: Telehealth Compliance and Use Issues: A Discussion with Christine Hall with Stirling Global Solutions

104

Importance of Documentation in Physician Financial Arrangements

105

DOJ 2023 Fiscal Year False Claims Act Settlements

106

The Connection (and Disconnect) between Commercial Reasonableness and Fair Market Value

107

Stark Law and Substance Abuse and Addiction

108

Fair Market Value under New Stark Law Regulations: A Discussion with Tim Smith from TS Healthcare Consulting

109

Employing Hospital-Based Specialists…Now What? A Discussion with Joe Aguilar and Natalie Bell from HMS Valuation Partners

110

Part 3: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP

111

Part 2: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP

112

Part 1: Learnings from the Community Health Network $345MM Settlement with Tim Smith from TS Healthcare Consulting and the AAPCP

113

Crisis Communication Management in Healthcare: A Discussion with Eileen Wixted from Wixted & Co.

114

Part 2: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower

115

Part 1: The Power of One: A Discussion with Frances Haugen, The Facebook Whistleblower

116

Part 2: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health

117

Part 1: OIG General Compliance Program Guidance: A Discussion with Alex Krouse with Parkview Health

118

Stark Law Holiday Poems: “'Twas the Night before the Subpoena,” “Rudy the Seasoned Compliance Officer,” and “Jolly OIG Agent”

119

Jolly OIG Agent: 2023 Stark Integrity Holiday Poem

120

Fixed Asset Valuations: A Discussion with Mike Vetter with HMS Valuation Partners

121

Recruitment and Physician Needs Assessment (PNA): A Discussion with Stephen Ross and Justin Chamblee from Coker Group

122

Medical Directors: Can't Live With Them, Can't Live Without Them

123

Stark Law Timing: 1 Year, 2 Years, 5 Years, and More Timing Limitations

124

Hospital-Based Financial Arrangements: A Discussion with Joe Aguilar with HMS Valuation Partners

125

Master List Requirement under the Stark Law Explained

126

Stark Law Settlements under the Self-Referral Disclosure Protocol (SRDP): How Long and How Much?

127

Stark Law Compliance Mash

128

History of Fair Market Value and Wade's Personal Impact on FMV Standard

129

Academic Medical Centers Exception: What Is It and How Can It Be Used?

130

Operational Challenges in Physician Financial Arrangements: Who Is Driving the Bus?

131

False Claims Act 2023 Mid-Year Review

132

CARES Act Fraud: Discussion with Bart Daniel from Nelson Mullins

133

Call Arrangements in the Healthcare Industry: Discussion with Ashley Graver from Coker Group

134

Civil and Criminal Investigations in the Healthcare Industry: Discussion with Bart Daniel from Nelson Mullins

135

Fair Market Value Analysis Mistakes

136

Time-Share Lease Arrangements in Healthcare: Conversation with Ron Young from The Advisory Group

137

Fair Market Value, Commercial Reasonableness, and Remuneration: Does FMV Cover All Sins?

138

False Claims Act: Supreme Court Holds Knowledge Is Subjective Not Objective: Discussion with Bart Daniel from Nelson Mullins

139

Part 2: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting

140

Part 1: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting

141

False Claims Act (FCA): Is Knowledge Objective or Subjective

142

Advanced Practice Providers (APPs): Compliance Risks and Safeguards

143

Eliminating Kickbacks in Recovery Act (EKRA): Comparison with the AKS

144

Part 2: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel

145

Part 1: Boots on the Ground: Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel

146

Stark Law and Anti-Kickback Issues with Healthcare Transactions

147

Unique Trends and Compliance Issues with Value-Based Reimbursement Arrangements: A Discussion with Christine Worthen of Nelson Mullins

148

Logos and Slogans to Promote an Effective Compliance Program

149

One Purpose Test: Greber vs. Holland; A discussion with Gabe Imperato with Nelson Mullins

150

Waiving Copays: Legal or Illegal?

151

DOJ 2022 False Claims Act Settlements and Judgments: Learning Points

152

Compliance Effectiveness: It Is about the Culture of the Organization

153

Value-Based Arrangements Key Issues: A Discussion with Kelly Conroy from Pinnacle Healthcare and Ed White from Nelson Mullins

154

Medical Necessity: A Major Compliance Issue and Risk

155

Audit Work Plan Development: The Who, What, and How

156

Corporate Practice of Medicine (CPOM) Compliance: A Discussion with Heather Miller from Nelson Mullins

157

Stark Law Holiday Poems: “'Twas the Night before the Subpoena” and "Rudy the Seasoned Compliance Officer”

158

Captain Integrity Holiday Message, including "Rudy the Seasoned Compliance Officer”

159

Compliance Program Development and Effectiveness: A Discussion with Chief Compliance Officer Steve Sugrue with DocGo

160

Creating Value through Compliance: A Conversation with Jerry Shafran, CEO of YouCompli

161

6 Deadly Mistakes in Value-Based Activities Compensation under Stark and AKS

162

What? The Stark Law Covers Physicians' Charitable Contributions of Money and Services?

163

Legal Independent Review Organization (IRO) Services Under (or Outside) a Corporate Integrity Agreement

164

Part 2: Children's Hospitals, Medicaid, and Stark Law Compliance: A Discussion with Andy Lenobel with Nationwide Children's Hospital

165

Part 1: Children's Hospitals, Medicaid, and Stark Law Compliance

166

Part 2: Examples of Interplay between Peer Review and Compliance, False Claims Act, and Stark Law

167

Part 1: Interplay between Peer Review and Compliance, False Claims Act, and Stark Law

168

Rare Qui Tam Jury False Claims Act Case: Learning Points Regarding FCA Cases Including Eli Lilly/Astellas Pharma Verdict

169

False Claims Act Settlement Updates - Midyear 2022: The Dollars and the Issues

170

Legal and Operational Issues with Accountable Care Organizations/Value Based Arrangements: A Discussion with Kelly Conroy with Pinnacle Healthcare Consulting

171

How to Respond to a Civil Investigative Demand (CID) Issued by the Department of Justice (DOJ)

172

Office of Inspector General (OIG) Self-Disclosure Protocol: Different from the CMS SRDP

173

How to Use the Self-Referral Disclosure Protocol (SRDP) to Voluntarily Report Stark Law Violations

174

Continuing Medical Education (CME): Fraud Issues and OIG Advisory Opinion 22-14

175

Compliance Experts and Monitors: What Are They and Why Are They Engaged?

176

Selecting a Compliance Officer: Why, What, Who?

177

Tick-Tock: Time Reports and Stark Law Compliance

178

Compensation Pools: Stark Law Lifeguard Training

179

K.I.S.S. the Stark Law

180

Shared Services Performed by Physicians and APPs: A Discussion with Amy Noecker and Zachary Hartsell from SullivanCotter

181

Physician Liability and Qui Tam Cases under the Stark Law and AKS: A Discussion with Marlan Wilbanks, Esq.

182

Physician Work Effort Tracking under the Stark Law: A Discussion with Gail Peace with Ludi, Inc.

183

Intent under the Stark Law: "But I Thought Stark Was Civil, Not Criminal"

184

Non-Physician Practitioner Recruitment under the Stark Law: Proceed with Caution

185

Current Physician Compensation Trends from the AAPCP Conference: A Discussion with Anthony Domanico from VMG Health

186

Part 2 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational Challenges

187

Part 1 Physician Recruitment under the Stark Law/AKS: The Regs, Settlements, and Operational Challenges

188

Life and Learnings from a CIA: A Discussion with Lucia Pizano-Urbina from Broward Health

189

Group Practice Part 2: Stark Law's In-Office Ancillary Services Exception

190

2021 CMS-Revised wRVUs and Impact on Physician Compensation: A Discussion with Bob Madden of SullivanCotter

191

Group Practices Part 1: The Mother of All Stark Law Definitions

192

Impact of COVID, 2021 wRVU Values, and 2022 Physician Fee Schedule on Fair Market Value and Stark Law Compliance

193

2021 Settlements Under the False Claims Act, Stark Law, and Anti-Kickback Statute - Lessons Learned

194

Business Valuations under AKS and Stark Law with Richard Romero from Coker Group

195

Stark Law, Fair Market Value, and Approval Process Discussion with Parkview Health Attorney Alex Krouse

196

Board Members Part 2: Compliance and Key Legal Requirements Including the Stark Law

197

Board Members Part 1: Compliance and Key Legal Requirements Including the Stark Law

198

Stark Law Emerging Trends: Commercial Reasonableness, Directed Referrals, NPP Supervision, Call, Quality, and Loss Arrangements

199

Stark Law Emerging Trends: Approval Process, FMV, 90th Percentile Compensation, and Independent Contractors

200

Real Estate II: Time Share Leasing Arrangements Under the Stark Law

201

Real Estate Compliance Under the Stark Law

202

Why is a Fair Market Value Defensibility Analysis Different from a FMV Review under the Stark Law?

203

Let's Make a Deal: Stark Law Compliance in the C-Suite

204

Stark Violations: Possible Stark Law Remedies

205

Physician Employment Agreements Under Stark Law

206

More Examples of Stark Law's Non-Monetary Compensation Exception

207

Stark Law's Non-Monetary Compensation Exception With Real Examples

208

Stark Law Holiday Poem: 'Twas The Night Before The Subpoena

209

Applying the Stark Law to Ownership and Compensation Arrangements - Direct and Indirect

210

Stark Law: 'Twas The Night Before The Subpoena

211

Stark Law’s Commercial Reasonableness Standard

212

Value-Based Arrangements: The Stark Law/AKS Requirements

213

What Are Some Examples of Fair Market Value Liability Under the Stark Law?

214

What Is the Practical Application of Fair Market Value Under the Stark Law?

215

Why Is Fair Market Value the Pinnacle Stark Law Issue?

216

What Are the Damages, Fines, and Penalties Under the Stark Law?

217

What Are the Stark Law Definitions?

218

Welcome to Stark Integrity: What Is the Stark Law?