All Episodes

The Misunderstood Commercial Reasonableness Test Explained and Fire Stations

Is CMS Proposing That Physicians Cannot Perform a Procedure on Same Day as E&M Encounter in 2027?

Implementing & Monitoring AI Responsibly: A Discussion with Arvita Tripati, Founder & Principal at Vahana Labs

Death by Committee? How to Run and Participate in a Compliance Committee Meeting That Actually Matters

Private Equity Meets the Stark Law: Navigating Physician Transactions, MSOs, Referral Risks…and Insects

Stark Integrity Podcast: Is It a Podcast? Is It a Blog? Is it Both?

Retraction

The Cost of Referrals: Erlanger’s $21M Stark Law Settlement

Using AI in Physician Contracting & Payment: A Discussion with Scott Lowry, Founder of StarkWatch

Part 3: Informed Consent, Decision-Making Capacity, and Surrogates: A Discussion with Attorney Rachel Rose

Part 2: Informed Consent, Decision-Making Capacity, and Surrogates: A Discussion with Attorney Rachel Rose

Part 1: Informed Consent, Decision-Making Capacity, and Surrogates: A Discussion with Attorney Rachel Rose

Part 2: Holistic Audits: Synchronizing Professional & Facility Reviews: A Discussion with Kelly Loya & Bruce Truitt, Pinnacle Enterprise

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

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

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

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

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

False Claims Act Settlements for 2025 (FCA)

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Health Law and Compliance Christmas Specials 2021 - 2025

2025 Christmas Episode with “Santa Baby” Parody

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

What? I Married the Stark Law?

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

“Personally Performed” Services and Autonomous Vehicles

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

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

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

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

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

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

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

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

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

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

Don’t Shoot the Messenger

Compliance Officer: You Are Not an Independent Auditor

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

Medical Staff Funds & The Stark Law

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

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

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

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

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

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

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

One Big Beautiful Bill’s Impact on Healthcare

Ethics and Compliance and Integrity in Physician Compensation Arrangements

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

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

Usual and Customary Charges with Medicare and Most Favored Nation Clauses

Referrals “Get the Ball Rolling”

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

Civil Investigative Demands (CID): Critical Steps for Responding

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

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

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

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

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

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

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

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

Best Practice Oversight of Physician Compensation Arrangements

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

2024 “Winners” for Most Egregious US Healthcare Profiteering

DHS Entity Defined and Tesla Example

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

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

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

The 12 Days of Compliance: 2024 Holiday Special

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

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

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

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

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

Restoring Our Sanity Online: A Discussion with Author Mark Weinstein

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

A Rare Bird: Fair Market Value for Key Opinion Leaders

Percentage Arrangements under the Stark Law

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

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

How to Identify Covert Retaliation

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

Does the Stark Law Have a De Minimis Exception?

Are wRVUs Physician Compensation's Holy Grail?

Volume or Value Conundrum

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

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

Importance of Documentation in Physician Financial Arrangements

DOJ 2023 Fiscal Year False Claims Act Settlements

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

Stark Law and Substance Abuse and Addiction

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

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

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

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

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

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

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

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

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

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

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

Jolly OIG Agent: 2023 Stark Integrity Holiday Poem

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

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

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

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

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

Master List Requirement under the Stark Law Explained

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

Stark Law Compliance Mash

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

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

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

False Claims Act 2023 Mid-Year Review

CARES Act Fraud: Discussion with Bart Daniel from Nelson Mullins

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

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

Fair Market Value Analysis Mistakes

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

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

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

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

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

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

Advanced Practice Providers (APPs): Compliance Risks and Safeguards

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

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

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

Stark Law and Anti-Kickback Issues with Healthcare Transactions

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

Logos and Slogans to Promote an Effective Compliance Program

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

Waiving Copays: Legal or Illegal?

DOJ 2022 False Claims Act Settlements and Judgments: Learning Points

Compliance Effectiveness: It Is about the Culture of the Organization

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

Medical Necessity: A Major Compliance Issue and Risk

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Selecting a Compliance Officer: Why, What, Who?

Tick-Tock: Time Reports and Stark Law Compliance

Compensation Pools: Stark Law Lifeguard Training

K.I.S.S. the Stark Law

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Real Estate Compliance Under the Stark Law

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

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

Stark Violations: Possible Stark Law Remedies

Physician Employment Agreements Under Stark Law

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

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

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

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

Stark Law: 'Twas The Night Before The Subpoena

Stark Law’s Commercial Reasonableness Standard

Value-Based Arrangements: The Stark Law/AKS Requirements

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

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

Why Is Fair Market Value the Pinnacle Stark Law Issue?

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

What Are the Stark Law Definitions?

Welcome to Stark Integrity: What Is the Stark Law?