Robert Wade

Bob has more than 25 years of experience in the healthcare industry and counsels clients on fraud and abuse issues, fair market value, commercial reasonableness and developing, monitoring, and documenting effective healthcare compliance programs. He serves clients nationally as a compliance professional and assists in negotiating and implementing corporate integrity agreements and in documenting and defending financial arrangements being of fair market value and commercially reasonable between healthcare providers. Bob has represented healthcare providers, including hospitals, large health systems, and referring physicians in such matters and has also represented healthcare clients under investigation by the U.S. Department of Justice and the Office of Inspector General.
Previously, Bob served as a general counsel and organizational integrity officer for a multi-hospital system, giving him first hand experience working with challenges faced across their organization. As a result, he is able to provide valuable and practical insight to his clients in complex healthcare legal matters that is also from an operational and regulatory perspective.
Bob is a frequent speaker at many national and regional healthcare legal, compliance, and regulatory conferences, including conferences sponsored by the American Health Lawyers Association and Health Care Compliance Association. He also provides his professional insight as the host of the Stark Integrity: The Stark Law and Compliance Podcast.

Education
The Ohio State University Moritz College of Law, JD, summa cum laude (1989)
? Managing editor of The Ohio State University Law Journal
? Order of the Coif
? Omicron Delta Kappa
Bowling Green State University, BA, summa cum laude (1986)

Admissions
District of Columbia

Indiana

Not Admitted in Tennessee

U.S. District Court for the Northern District of Indiana

Practice Areas
Healthcare Providers & Suppliers

Healthcare Government Investigations & Litigation

Healthcare Regulatory, Compliance & Operations

Healthcare Qui Tam Investigations & Litigation

Healthcare Transactions

White Collar Healthcare Fraud, Compliance & Litigation

Taxable & Tax Exempt Entities

Industries
Healthcare




Experience:
? Served as the compliance professional to the Board of Commissioners for Halifax Health in Daytona Beach, Florida during Halifax?s five-year CIA to monitor compliance with CIA and provide compliance effectiveness reviews submitted to the Office of the Inspector General
? Filed several self-reports under the Office of Inspector General Self-Disclosure Protocol and negotiated settlement agreements
? Filed several self-reports under the Centers for Medicare and Medicaid Services Self-Referral Disclosure Protocol for violations under the Stark Law and negotiated settlement agreements
? Assisted healthcare entities, including consulting entities, in responding to civil investigative demands from the Department of Justice
? Assisted healthcare entities who were the target of the Department of Justice in responding to subpoenas, litigation, and settlement with Department of Justice and qui tam litigants
? Performed several fair market value/commercial reasonableness defensibility analysis for physician/provider compensation arrangements from single compensation arrangements to evaluation of entire networks
? Performed several Internal Investigations related to healthcare fraud and abuse
? Assisted several healthcare entities in evaluating and defending billing/documentation reviews conducted by payers, including Medicare and Medicaid, including filing of appeals
? Served as a witness regarding various healthcare compliance and regulatory matters, including matters related to the Stark Law
? Assisted several healthcare entities in negotiation issues with the Department of Justice
? Assisted several healthcare entities with transactional arrangements for compliance with Stark Law ownership restrictions
? Developed value-based arrangements between hospital entities and medical staff members, both independent and employed
? Performed compliance effectiveness reviews with enhancement recommendations
? Structured arrangements to comply with discount safe harbor under Anti-Kickback Statute
? Represented healthcare providers and consultants in depositions before the Department of Justice

Recognitions:
The bar rules of some states require that the standards for an attorney?s inclusion in certain public accolades or recognitions be provided. When such accolades or recognitions are listed, a hyperlink is provided that leads to a description of the respective selection methodology.
? The Best Lawyers in America®, Health Care Law (2009?2024)
? Indiana Super Lawyers, Healthcare, 2009-2022

Professional Activities
? Editorial advisory board, Strategies for Health Care Compliance
? Editorial advisory board, Report on Medicare Compliance
? American Association of Provider Compensation Professionals Credential Advisory Council
? American Association of Provider Compensation Professionals Corporate Advisory Council

Leadership
? Editorial advisory board, Strategies for Health Care Compliance
? Editorial advisory board, Report on Medicare Compliance
? American Association of Provider Compensation Professionals Credential Advisory Council
? American Association of Provider Compensation Professionals Corporate Advisory Council

Articles & Speeches
Insights
Health System Settles Case on Free CME; It Self-Disclosed After Internal Review, Report on Medicare Compliance Volume 31, Number 42 - Contributor (November 22, 2022)
Value-Based Activities Compensation: Can We Throw Fair Market Value Out the Window, The Journal of Health Care Compliance - Author (May - June 2022)
2021 Complete Healthcare Compliance Manual, Contracts with Referral Sources: Entering into a Proper Physician Arrangement and Contracts with Referral Sources: Importance of Monitoring These Arrangements, The Health Care Compliance Association - Chapter author (2021)
2022 Complete Healthcare Compliance Manual, Contracts with Referral Sources: Entering into a Proper Physician Arrangement and Contracts with Referral Sources: Importance of Monitoring These Arrangements, The Health Care Compliance Association - Chapter author (2022)
The Compliance Officer?s Handbook, Fourth Edition, HCPro, Inc., Marblehead, Mass. - Co-Author (May 2020)
Legal Requirements Concerning Physician Compensation, The Healthcare Compliance Professional?s Manual, Second Edition, Wolters Kluwer - Chapter author (2019)
Health Law Handbook, Chapter III. Fraud & Abuse, Title: Corporate Integrity Agreements: Living Under a Corporate Integrity Agreement and What Can The Industry Learn from Corporate Integrity Agreements, Health Law Series, 29th Edition - Chapter author (May 2018)
Understanding ACA Regulatory Issues: Ripple Effect Continues for Hospitals and other Health Care Organizations, Building Indiana - Author (May 2014)
Exchange Health Plans Are Not Considered Federal Health Care Programs? HHS Limits the Anti-Kickback Statute, American Health Lawyers Association Connections - Author (February 2014)
Feds Focus on EHR Fraud and Abuse ? Understanding the Risks of Upcoding, Overpayment, and the False Claims Act, Chicago Medicine - Co-Author (January 2014)
Events/Speaking Engagements
HCCA Hawaii Regional Healthcare Compliance Conference - Speaker (October 13, 2023)
Trending Fraud and Abuse Developments and How to Address Them - Speaker (August 1, 2023)
2023 Annual Meeting - Speaker (June 26, 2023)
May 2023 Healthcare General Counsel Forum - Speaker (May 8, 2023)
33rd Annual National Institute on Health Care Fraud - Speaker (May 3, 2023)
National Provider Compensation Conference - Speaker (April 26, 2023)
27th Annual Compliance Institute - Speaker (April 23, 2023)
Physicians and Hospitals Law Institute: ?Complex Stark Issues (CSI)? - Speaker (February 1, 2023)
Orlando Regional Conference: ?Recent Developments in Kickback and Stark Law? - Speaker (January 22, 2023)
Strafford Conferences, ?Due Diligence for Compensation Compliance: Mitigating Risk in Financial Relationships and Healthcare Transactions? - Speaker (November 8, 2022)
Healthcare Enforcement Compliance Conference - Co-Speaker (November 7, 2022)
Nelson Mullins Value-Based Care Conference 2022: Hot Topics and Trends - Panelist (November 3, 2022)
Health Care Compliance Association, HCCA Hawaii Regional Conference, ?Reportable Events: How to Investigate, Respond, Self-Report and Alternatives to Self-Reporting? - Speaker (October 13, 2022)
Health Care Compliance Association, HCCA Clinical Practice Compliance Conference, ?Stark Law Group Practice Definition and In-Office Ancillary Services Exception: Do We Comply?? - Speaker (October 11, 2022)
American Bar Association, Physicians Legal Issues: Healthcare Delivery & Innovation Conference, ?Debating Fair Market Value Post-2020? - Speaker (September 15, 2022)
Health Care Compliance Association, HCCA Compliance Institute, ?2022 Updates on Stark Regulations and Impacts of Fair Market Value/Commercial Reasonableness,? - Speaker (June 28, 2022)
American Association of Provider Care Professionals, 2022 National Provider Compensation Conference, ?Provider Compensation Fair Market Value/Commercial Reasonableness Management: Case Study of Halifax Health? - Speaker (May 5, 2022)
Fundamentals of Physician Compensation - Speaker (April 5, 2022)
Health Care Compliance Association, HCCA Compliance Institute, ?Emerging Trends in Physician Employment/Independent Contractor Contracting and Compensation Arrangements with Hospitals? - Speaker (March 28, 2022)
Health Care Compliance Association, HCCA Compliance Institute, ?Reportable Events: How to Investigate, Respond, Self-Report, and Alternatives to Self-Reporting? - Speaker (March 28, 2022)
American Health Law Association, AHLA Academic Medical Centers Conference, ?Emerging Trends in Physician Employment/Independent Contractor Contracting and Compensation Arrangements with Hospitals" - Speaker (February 15, 2022)
AHLA Physicians and Law Institute, ?Emerging Trends in Physician Employment/Independent Contractor Contracting and Compensation Arrangements with Hospitals - Speaker (February 4, 2022)
American Health Law Association, AHLA Physicians and Hospitals Law Institute Conference, ?Emerging Trends in Physician Employment/Independent Contractor Contracting and Compensation Arrangements with Hospitals" - Speaker (February 2, 2022)
Health Care Compliance Association, HCCA?s 7th Annual Healthcare Enforcement Compliance Conference, ?101 Ask the Stark Professionals" - Speaker (November 8, 2021)
Nelson Mullins Annual Health Care Forum, ?Ask the Stark Law Professionals" - Speaker (November 2, 2021)
Health Care Compliance Association, HCCA Chicago Regional Conference, ?Compliance Management of Physician Financial Arrangements: Commercial Reasonableness, FMV, Approval Process, and Payment Oversight in Light of Final Stark Rules" - Speaker (October 22, 2021)
Health Care Compliance Association, HCCA Hawaii Regional Conference, ?The Stark Law: Help Me Understand!? - Speaker (October 7, 2021)
American Association of Provider Compensation Professionals, ?Stark Law and Anti-Kickback Statute 2021 Revisions and New Exceptions and Safe Harbor" - Speaker (August 24, 2021)
American Health Law Association, ?Governance and Buyer Neutral Framework in Fair Market Value Compensation Arrangements" - Speaker (August 24, 2021)
Health Care Compliance Association, HCCA?s 25th Annual Compliance Institute, ?Ask the Stark Law Professionals? - Speaker (April 19, 2021)
Health Care Compliance Association, HCCA?s 25th Annual Compliance Institute, ?Emerging Trends in Physician Employment/Independent Contractor Contracting and Compensation Arrangements with Hospitals" - Speaker (April 19, 2021)
Health Care Compliance Association, ?New Stark Regulations and Impact on Fair Market Value/Commercial Reasonableness" - Speaker (April 6, 2021)
American Health Lawyers Association, ?New Stark Regulations and Impact on Fair Market Value/Commercial Reasonableness - Speaker (January 19, 2021)
American Association of Provider Compensation Professionals (AAPCP) Audio Webinar, "Stark, Anti-Kickback, and Physician Fee Schedule Final Rules Expert Roundtable" - Speaker (December 1, 2020)
Health Care Compliance Association Compliance Enforcement Conference, "Ask the Stark Professional" - Speaker (November 17, 2020)
Health Care Compliance Association Compliance Enforcement Conference, "Stark Law Current Issues and Trends" - Speaker (November 16, 2020)
Health Care Compliance Association HCCA Compliance Enforcement Conference, "Ask the Stark Law Professionals" - Speaker (November 15, 2020)
Indiana State Bar Association Annual Law Symposium, "Emerging Trends in Physician/Hospital Compensation Arrangements--Regulatory Considerations, Fair Market Value/Commercial Reasonableness Conundrum and Oversight" - Speaker (November 10, 2020)
American Association of Provider Compensation Professionals (AAPCP) Audio Webinar, ?Hear from the Experts: Should Health Systems Implement the 2021 Physician Fee Schedule wRVU Changes for Providers on Production? How Will it Impact FMV and CR Defensibility?? - Speaker (October 15, 2020)
American Association of Provider Compensation Professionals (AAPCP) Webinar, ?Provider compensation Governance: Creating a Defensible Process for Developing and Managing Provider Compensation" - Speaker (October 6, 2020)
Strafford Webinar, "Whistleblower and Retaliation Claims in Healthcare: Compliance Programs, Current Political Climate, Mitigation Risks" - Speaker (August 27, 2020)
Strafford Webinar, ?Valuation Challenges in Physician Compensation Arrangements: Meeting Compliance and Regulatory Requirements" - Speaker (August 4, 2020)
American Association of Provider Compensation Professionals (AAPCP), ?Provider Compensation and COVID-19: Where We Have Been, Where We Are, and Where Are We Going?" - Speaker (June 25, 2020)
American College of Foot & Ankle Surgeons, ?COVID-19 Issues: Compensation, Fraud and Abuse, Practice Expenses, Telemedicine, and Insurance" - Speaker (April 1, 2020)
American Association of Provider Compensation Professionals, "Stark Law Fair Market Value/Commercial Reasonableness Issues related to COVID ? 19" - Speaker (March 27, 2020)
Health Care Compliance Association Enforcement Compliance Conference, ?Ask the Stark Law Professionals" - Speaker (November 4, 2019)
Health Care Compliance Association, 2019 Healthcare Enforcement Compliance Conference, "Ask the Stark Law Professionals" - Speaker (November 3, 2019)
Health Care Compliance Association, HCCA Hawaii Regional Healthcare Compliance Conference, "Effective Compliance Oversight for Physician Financial Arrangements" - Speaker (October 10, 2019)
Lorman Webinar, ?Medical Record Audits: What You Need to Know About Payor Provider and Government Reviews" - Speaker (September 16, 2019)
AHLA Health Care Transactions, ?Navigating Through Commercial Reasonableness/Fair Market Value Issues When Conducting Due Diligence" - Speaker (May 1, 2019)
Health Care Compliance Association Honolulu Regional Conference, ?Physician Compensation Arrangements" - Speaker (October 11, 2018)
Legal Publishing Group of Strafford Webinar, ?Structuring Call Coverage Agreements: Regulatory Concerns and Practical Suggestions" - Speaker (September 6, 2018)
Clear Law Institute Webinar, ?False Claims Update" - Speaker (May 23, 2018)
Health Care Compliance Association, ?Compliance Program Effectiveness - Measuring and Reporting it to the Government" - Speaker (May 17, 2018)
Lorman Education Services - Live Webinar, ?Fundamentals of Physician Compensation" - Speaker (May 14, 2018)
American Bar Association, 28th Annual National Institute on Health Care Fraud, ?Compliance Program Effectiveness ? Measuring and Reporting it to the Government" - Speaker (May 2, 2018)
Health Care Compliance Association 22nd Annual Compliance Institute ?Ask the Stark Law Professionals? - Speaker (April 15, 2018)
Health Care Compliance Association 23rd Annual Compliance Conference "Ask the Stark Law Professionals" - Speaker (April 7, 2018)
Lorman Education Services - Live Webinar, ?False Claims Act Update" - Speaker (February 21, 2018)
American Health Lawyers Association (AHLA), ?Sharing the Load: Maximizing the Working Relationship Between Management, Finance, Legal, Compliance, Outside Counsel and Appraiser in the Physician Compensation Process" - Speaker (February 7, 2018)
Health Care Compliance Association Florida, ?Corporate Integrity Agreements and Compliance Program Effectiveness" - Speaker (February 2, 2018)
Health Care Compliance Association, Enforcement Compliance Institute, ?Corporate Integrity Agreements: Living under a CIA or using CIAs to Shape Legal/Compliance programs - Speaker (October 29, 2017)
Health Care Compliance Association, Enforcement Compliance Institute, ?Ask the Stark Law Professionals: Q&A Session" - Speaker (October 29, 2017)
Health Care Compliance Association, Honolulu Regional Conference, ?Advanced Fair Market Value: Complex Hospital-Physician Compensation Arrangements" - Speaker (October 12, 2017)
American Bar Association Health, 27th Annual National Institute on Health Care Fraud, Moderator: ?Board, Management and Governance for Organizational Compliance" - Speaker (May 17, 2017)
American Health Lawyers Association (AHLA) Health Care Transaction, ?What Lessons Have We Learned from Halifax, Tuomey, North Broward, Adventist, and Columbus Regional Health" - Speaker (April 27, 2017)
America Health Lawyers Association, Academic Medical Centers (AMC) Conference, "2017 Fraud and Abuse Update for AMCs" - Speaker (March 9, 2017)
Health Care Compliance Association (HCCA) Conference, "What We Have Learned: From Halifax, Tuomey, North Broward, Adventist and Columbus Regional and Current Legal Issues" - Speaker (March 3, 2017)
Lorman webinar, "Update on False Claims Act" - Speaker (February 20, 2017)
Blogs
Stark Integrity Podcast: Civil and Criminal Investigations, FMV, and Time-Share Lease Arrangements Episodes, Healthcare Essentials - Host (August 14, 2023)
Stark Integrity Podcast: False Claims Act: Supreme Court Holds Knowledge Is Subjective Not Objective Episode, Healthcare Essentials - Host (July 11, 2023)
Physician Wellness Program Exception, Healthcare Essentials - Co-Author (June 21, 2023)
Stark Integrity Podcast: Split and Shared Billing, FCA, and AAPs Episodes, Healthcare Essentials - Host (June 13, 2023)
Stark Integrity Podcast: Tuomey Case Part 1 and 2 and EKRA Compared to AKS Episodes, Healthcare Essentials - Host (May 11, 2023)
Stark and Legal Learnings from the Tuomey Case with Nelson Mullins Partner Bart Daniel, Investigations - Host (April 24, 2023)
Stark Integrity Podcast: Logos and Slogans, Value-Based Reimbursement Arrangements, and Stark Law and Anti-Kickback Issues Episodes, Healthcare Essentials - Host (April 12, 2023)
One Purpose Test: Greber vs. Holland; A discussion with Gabe Imperato with Nelson Mullins, Investigations - Host (April 6, 2023)
Stark Integrity Podcast: One Purpose Test, Waiving Copays, FCA Learning Points, and Compliance Effectiveness Episodes, Healthcare Essentials - Host (March 10, 2023)
Stark Integrity Podcast: Value-Based Arrangements, Medical Necessity, and Audit Work Plan Development Episodes, Healthcare Essentials - Host (February 15, 2023)
Corporate Practice of Medicine (CPOM) Compliance: A Discussion with Heather Miller from Nelson Mullins, Healthcare Essentials - Host (January 19, 2023)
Captain Integrity Holiday Message, including 'Rudy the Seasoned Compliance Officer', Healthcare Essentials - Host (November 30, 2022)
Fair Market Value Defensibility Analysis: Why is It Different from a Fair Market Value Opinion?, Healthcare Essentials - Author (October 20, 2022)