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All Episodes

Stark Integrity — 228 episodes

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Title
1

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

2

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

3

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

4

Retraction

5

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

6

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

7

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

8

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

9

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

10

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

11

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

12

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

13

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

14

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

15

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

16

False Claims Act Settlements for 2025 (FCA)

17

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

18

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

19

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

20

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

21

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

22

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

23

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

24

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

25

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

26

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

27

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

28

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

29

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

30

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

31

Health Law and Compliance Christmas Specials 2021 - 2025

32

2025 Christmas Episode with “Santa Baby” Parody

33

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

34

What? I Married the Stark Law?

35

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

36

“Personally Performed” Services and Autonomous Vehicles

37

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

38

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

39

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

40

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

41

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

42

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

43

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

44

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

45

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

46

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

47

Don’t Shoot the Messenger

48

Compliance Officer: You Are Not an Independent Auditor

49

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

50

Medical Staff Funds & The Stark Law

51

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

52

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

53

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

54

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

55

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

56

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

57

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

58

One Big Beautiful Bill’s Impact on Healthcare

59

Ethics and Compliance and Integrity in Physician Compensation Arrangements

60

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

61

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

62

Usual and Customary Charges with Medicare and Most Favored Nation Clauses

63

Referrals “Get the Ball Rolling”

64

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

65

Civil Investigative Demands (CID): Critical Steps for Responding

66

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

67

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

68

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

69

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

70

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

71

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

72

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

73

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

74

Best Practice Oversight of Physician Compensation Arrangements

75

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

76

2024 “Winners” for Most Egregious US Healthcare Profiteering

77

DHS Entity Defined and Tesla Example

78

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

79

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

80

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

81

The 12 Days of Compliance: 2024 Holiday Special

82

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

83

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

84

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

85

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

86

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

87

Restoring Our Sanity Online: A Discussion with Author Mark Weinstein

88

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

89

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

90

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

91

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

92

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

93

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

94

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

95

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

96

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

97

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

98

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

99

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

100

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

101

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

102

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

103

A Rare Bird: Fair Market Value for Key Opinion Leaders

104

Percentage Arrangements under the Stark Law

105

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

106

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

107

How to Identify Covert Retaliation

108

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

109

Does the Stark Law Have a De Minimis Exception?

110

Are wRVUs Physician Compensation's Holy Grail?

111

Volume or Value Conundrum

112

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

113

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

114

Importance of Documentation in Physician Financial Arrangements

115

DOJ 2023 Fiscal Year False Claims Act Settlements

116

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

117

Stark Law and Substance Abuse and Addiction

118

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

119

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

120

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

121

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

122

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

123

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

124

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

125

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

126

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

127

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

128

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

129

Jolly OIG Agent: 2023 Stark Integrity Holiday Poem

130

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

131

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

132

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

133

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

134

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

135

Master List Requirement under the Stark Law Explained

136

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

137

Stark Law Compliance Mash

138

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

139

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

140

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

141

False Claims Act 2023 Mid-Year Review

142

CARES Act Fraud: Discussion with Bart Daniel from Nelson Mullins

143

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

144

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

145

Fair Market Value Analysis Mistakes

146

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

147

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

148

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

149

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

150

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

151

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

152

Advanced Practice Providers (APPs): Compliance Risks and Safeguards

153

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

154

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

155

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

156

Stark Law and Anti-Kickback Issues with Healthcare Transactions

157

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

158

Logos and Slogans to Promote an Effective Compliance Program

159

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

160

Waiving Copays: Legal or Illegal?

161

DOJ 2022 False Claims Act Settlements and Judgments: Learning Points

162

Compliance Effectiveness: It Is about the Culture of the Organization

163

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

164

Medical Necessity: A Major Compliance Issue and Risk

165

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

166

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

167

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

168

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

169

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

170

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

171

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

172

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

173

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

174

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

175

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

176

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

177

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

178

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

179

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

180

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

181

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

182

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

183

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

184

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

185

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

186

Selecting a Compliance Officer: Why, What, Who?

187

Tick-Tock: Time Reports and Stark Law Compliance

188

Compensation Pools: Stark Law Lifeguard Training

189

K.I.S.S. the Stark Law

190

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

191

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

192

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

193

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

194

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

195

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

196

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

197

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

198

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

199

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

200

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

201

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

202

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

203

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

204

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

205

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

206

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

207

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

208

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

209

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

210

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

211

Real Estate Compliance Under the Stark Law

212

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

213

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

214

Stark Violations: Possible Stark Law Remedies

215

Physician Employment Agreements Under Stark Law

216

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

217

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

218

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

219

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

220

Stark Law: 'Twas The Night Before The Subpoena

221

Stark Law’s Commercial Reasonableness Standard

222

Value-Based Arrangements: The Stark Law/AKS Requirements

223

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

224

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

225

Why Is Fair Market Value the Pinnacle Stark Law Issue?

226

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

227

What Are the Stark Law Definitions?

228

Welcome to Stark Integrity: What Is the Stark Law?