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Law Professional

P: (574) 485-2002
F: (574) 277-1201
C: (574) 274-0432

MY WEBSITE:              
Captain Integrity

South Bend / Mishawaka Office
4101 Edison Lakes Parkway
Suite 100
Mishawaka, IN 46545

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Practice and Industry Teams

Robert A. Wade


Bob Wade is the Chair of the firm's Health Care Practice Group. He concentrates his practice in representing health care clients, including large health systems, hospitals, ambulatory surgical centers, physician groups, physicians and other medical providers. His expertise includes representing clients with respect to the Stark Act, Anti-Kickback Statute, False Claims Act, and Emergency Medical Treatment and Active Labor Act.

Bob is also nationally recognized in all aspects of health care compliance, including
developing, monitoring and documentation of an effective compliance program. He has
experience in representing health care clients with respect to issues being investigated by the
Department of Justice and the Office of Inspector General. Bob has experience negotiating
and implementing Corporate Integrity Agreements. His expertise includes assisting clients in
documenting and defending financial arrangements between health care providers, including
referring physicians, as being fair market value and commercially reasonable. Bob has
operationally practical experience having served as a General Counsel and Organizational
Integrity Officer for a multi-hospital system for 6½ years.

Bob is also the creator of Captain Integrity (, a unique compliance
program branding and education resource that has received national recognition and has been
used by many hospitals, health systems and other providers. In addition to Bob’s health care
experience, he has counseled public and private companies, partnerships and other business
entities in general business matters, as well as matters involving professional sports and
mergers and acquisitions.

Representative Experience

  • Assisted hospitals and physician groups in conducting Stark Law reviews and implementing corrective actions
  • Represented hospitals in several self-disclosures regarding Stark Law violations using the Centers for Medicare and Medicaid Services' Self-Referral Disclosure Protocol
  • Representing large medical center in the development of a new hospital campus in South Bend, Indiana
  • Represented a large hospital system during the negotiations of a corporate integrity
    agreement with the Office of Inspector General
  • Assisted hospitals and physician groups on joint ventures, including imaging joint ventures and hospital joint ventures
  • Represented physicians and hospitals on investigations initiated by the Office of Inspector General, Department of Justice and payors, including Medicare and Medicaid
  • Representing several health systems, hospitals and physician groups on evaluating compensation arrangements with physicians to determine if compensation can be defended as fair market value and commercially reasonable
  • Served as Independent Review Organization for organization subject to Corporate Integrity Agreement
  • Assisted hospital system Institutional Review Board (IRB) and Compliance Department to validate billing and regulatory compliance for clinical research services


  • Bowling Green State University (B.A., summa cum laude, 1986)
  • The Ohio State University, Moritz College of Law, Columbus, Ohio (J.D., summa cum laude, 1989)
    • The Ohio State University Law Journal, Managing Editor, 1988-1989 

Bar Admissions

  • Indiana, 1993
  • U.S. District Court Northern District of Indiana, 1993

Seminars and Presentations

  • "CSI: Complex Stark Implementation," - American Society for Health Care Risk Management - 2014 Annual Conference, Anaheim, CA, October 26-29, 2014
  • "Fair Market Value Issues with Research Physicians," - Health Care Compliance Association: 2014 Research Compliance Conference - Austin, TX, June 1-4, 2014
  • "Fraud and Abuse Issues Impacted by the Affordable Care Act," - Health Care Compliance Association: 2014 HCCA Regional Conference - Columbus, OH, May 9, 2014
  • "Advanced Stark and Fair Market Value: A Progressive Case Study," - Health Care Compliance Association: HCCA 18th Annual Compliance Institute Conference - San Diego, CA, March 30-April 2, 2014
  • "Best Practices in Demonstrating Compliance Effectiveness," - Health Care Compliance Association: 2014 HCCA Regional Conference - St. Louis, MO, March 7, 2014
  • "Complex Stark Implementation and Self Disclosure," - American Health Lawyers Association: 2014 Physicians and Physician Organizations Law Institute - New Orleans, LA, February 5-7, 2014
  • "2014 Fraud and Abuse Update for AMCs," - Academic Medical Centers Program - Washington, D.C., January 23-24, 2014
  • "Anti-Kickback Statute: Safe Harbors and Fair Market Value/Commercial Reasonableness Requirements," - 2013 Healthcare Consulting Workshop - Las Vegas, NV, December 9-14, 2013
  • "What the Government Thinks About EHR Templates and Medical Record Cloning," - Indiana State Medical Association, Indiana Medical Group Management Association, Indiana Healthcare Financial Management Association and Integrity Health Strategies Consulting Group - Carmel, IN, November 21, 2013
  • "Fraud and Abuse Issues Related to Complex Fair Market Value Arrangements," - NACVA Fraud Healthcare Webinar, November 15, 2013
  • "New Governmental Focuses on Fraud and Abuse Enforcement," - Indiana Healthcare Symposium Sponsored by ACHE, HFMA, HIMMS, and IHIMA - Indianapolis, IN, November 13-14, 2013
  • "Responding to Technical Violations of the Stark Law," - Health Care Compliance Association - Webinar, November 6, 2013
  • "Setting Sail:  Physician Recruitment and Collaboration," - Annual Corazon Conference - Making Waves: Capture Momentum for Service Line Growth - Naples, FL, October 16-17, 2013
  • "Advanced Operational Challenges with Implementing Stark," - National Constitution Conference - Webinar, October 9, 2013
  • "Stark Self-Disclosure (Dos & Don'ts)," - The Healthcare Roundtable for General Counsel - Austin, TX, September 9, 2013
  • "Trustee Liability - This May Get Personal," - Minnesota Hospital Association - 2013 Annual Trustee Conference - Alexandria, MN, July 12-14, 2013
  • "The Non-Monetary Compensation Arrangement and Medical Staff Incidental Benefit Exceptions: When to give, how to track, and how to calculate benefits," ComplianceOnline Webinar - Nationwide, July 9, 2013
  • "CSI: Complex Stark Implementation," American Health Lawyers Association - 2013 Annual Meeting - San Diego, CA, June 30-July 3, 2013
  • "Compliance Issues, GGovernment Investigations, Settlements and False Claims Update," ComplianceOnline Webinar - Nationwide, June 13, 2013
  • "Fair Market Value Issues with Research Physicians," Health Care Compliance Association - 2013 Research Compliance Conference - Austin, TX, May 30-June 8, 2013
  • "Complex Fair Market Value/Commercial Reasonableness Compensation Issues," 4th Annual Indiana State Bar Association Health Law Conference - Indianapolis, IN, May 21, 2013
  • "EMTALA Guidelines & Regs in 2013: Stay CMS Compliant," Progressive Healthcare Webinar - Nationwide, April 30, 2013
  • "Managing Physician Relationships under ACOs/CMS Self Disclosure Process," Catholic Health Association Chief Compliance Officer's Meeting - National Harbor, MD, April 24, 2013 
  • "Practical Strategies for Minimizing Stark Risk," Health Care Compliance Association - 17th Annual Compliance Institute, National Harbor, MD, April 21-24, 2013
  • "Complex Fair Market Value/Commercial Reasonableness Compensation Issues," American Health Lawyers Association - Hospitals and Health Systems Law Institute, Phoenix, AZ, February 12-13, 2013
  • "Complex Fair Market Value/Commerical Reasonableness Compensation Issues," American Health Lawyers Association - Physicians and Physician Organizations Law Institute, Phoenix, AZ, February 11-12, 2013
  • "Fraud and Abuse for Academic Medical Centers and Teaching Hospitals," American Health Lawyers Association/National Association of College and University Attorneys, Washington, D.C., January 24-25, 2013
  • "Valuation Considerations in the Health Care Sector regarding the Anti-Kickback Statute, the Stark Law and False Claims Act," Consultants' Training Institute - 2012 Healthcare Consulting Workshop, Las Vegas, NV, December 11-14, 2012
  • "Stark Law: Making the Confusing Understandable," Medical Group Management Association - 2012 Annual Conference, San Antonio, TX, October 21-21, 2012
  • "Quality of Care: How can this be a Fraud Issue?," Inquisit - Audio Conference, Nationwide, October 9, 2012
  • "Risk Managers and Fraud & Abuse Risks: 2012 Best Practices," American Society for Health Care Risk Management - 2012 Annual Conference, Washington, D.C., October 7-10, 2012
  • "Stark Primer," American Health Lawyers Association/Health Care Compliance Association Fraud and Compliance Forum, Baltimore, MD, September 30-October 2, 2012
  •  "Compliance and Legal Interaction and Liability," Indiana University Law School - Compliance Conference, Indianapolis, IN, September 19, 2012
  • "Fair Market Value Boot Camp Kickoff: Introduction to Hypothetical Case Study with Discussion of Attorney and Valuator Practical Tips on Valuation Engagement," American Health Lawyers Association - 2012 Annual Meeting, Chicago, IL, June 23-27, 2012
  • "Fair Market Issues in Financial Arrangements with Research Physicians," Health Care Compliance Association's - 2012 Research Compliance Conference, Austin, TX, June 3-6, 2012
  • "Compliance Issues, Government Investigations, Settlements and False Claims Update," Health Care Administrators Association - Spring Conference 2012, New Orleans, LA, May 2-4, 2012
  • "Anti-Kickback, Stark and False Claims Act Liability," 2012 Health Care Compliance Association - Compliance Institute, Las Vegas, NV, April 29-May 2, 2012
  • "Risk Managers and Fraud & Abuse Risks: 2012 Best Practices," Indiana Society for Healthcare Risk Management - 2012 Spring Conference, Indianapolis, IN, April 20, 2012
  • "Understanding the Government's Weapons: New ways they are curtailing the Anti-Kickback Statute, Stark Law, and False Claims Act," Inquisit - Audio Conference, Nationwide, April 5, 2012
  • "Stark Law Auditing and Financial Arrangement Rehabilitation," Health Care Compliance Association - Web Conference, Nationwide, March 22, 2012
  • "EMTALA Updates & How to Avoid Violations," Progressive Healthcare Conferences - Webinar, Nationwide, March 13, 2012
  • "On-Call Compensation: Market Trends, Fair Market Value and Commercial Reasonableness, and Government Oversight," Hospitals and Health Systems Law Institute, American Health Lawyers Association, Orlando, FL, February 8-9, 2012
  • "Stark's Non-Monetary Compensation and Incidental Benefits Exceptions and Stark Audits: How to Conduct," 2012 Region 11 Symposium, Health Finance Management Association, Las Vegas, NV, January 29-February 1, 2012
  • "2012 Fraud and Abuse Development for AMC's," 2012 Academic Medical Center Conference, American Health Lawyers Association, Washington, D.C., January 26-27, 2012
  • “Documenting Compliant and FMV Physician Financial Arrangements,” Medical Group Management Association Annual Conference, Las Vegas, NV, October 23-26, 2011
  • "Update Regarding OIG and CMS Initiatives," Health Care Compliance Association, Indianapolis, IN, October 3, 2011
  • "Hospital/Physician Alliances Based on Fair Market Value for Service," Annual Krieg DeVault - ISMA - IMGMA Conference, Carmel, IN, September 29, 2011
  • "Radiology Regulatory Changes," Indianapolis, IN, August 17, 2011
  • "Stark Act Enforcement: Auditing for Stark Compliance and the Self Referral Disclosure Protocol," Healthcare Finance Management Association, Nationwide, July 14, 2011
  • “Advanced Operational Challenges with Implementing Stark,” In-House Counsel Program, American Health Lawyers Association, Boston, MA, June 26-29, 2011
  • "Health Care Reform Changes to Stark Law and Operational Challenges," Inquisit, Nationwide, June 21, 2011
  • “Fraud and Abuse Primer: Anti-Kickback Statute and Stark Act”, Annual Consultants Conference, National Association of Certified Valuators and Analysts/Institute of Business Appraisers, San Diego, CA, June 8-11, 2011
  • “Stark Act Enforcement: Self-Disclosure, Fair Market Value, and Non-Monetary Compensation,” Health Care Compliance Association, Columbus, OH, May 6, 2011
  • “Fair Market Value Hot Issues,” Inquisit, Nationwide, April 20, 2011
  • "RAC Audits in the IRF: Preventing Denials and Writing Strong Appeals," Health Care Compliance Association, Orlando, FL, April 12, 2011
  • “To Give or Not to Give: A Comprehensive Analysis of Stark’s Nonmonetary Compensation Exception,”, Second Presentation, National Compliance Institute, Health Care Compliance Association, Orlando, FL, April 10-13, 2011
  • “Hospital/Physician Integration Models: Co-Management Arrangements," Nationwide, April 13, 2011
  • “How to Implement an Effective Compliance Program in the Hospice Sector”, Management and Leadership Conference, The National Hospice and Palliative Care Organization, National Harbor, MD, April 7-9, 2011
  • “2011 EMTALA Update: When You Can & Cannot Refuse Treatment,” Nationwide Webinar, March 10, 2011
  • “Stark Self Disclosure,” Hospital & Health System Conference, American Health Lawyers Association, Las Vegas, NV, February 10-12, 2011
  • “Stark, Anti-Kickback, and False Claims Act Issues for Academic Medical Centers: How Healthcare Reform Will Shift the Playing Field”, Legal Issues Affecting Academic Medical Centers Conference, American Health Lawyers Association, Washington, D.C., January 27-28, 2011
  • “Healthcare Regulatory Compliance Issues: What’s Hot Today?”, NACVA and IBA, Miami, FL, June 2-25, 2010
  • “Fraud and Abuse Update”, Health Care Compliance Association, Columbus, OH, May 7, 2010
  • “Fraud and Abuse Update”, HFMA, Honolulu, HI, April 27-28, 2010
  • “Avoid Fair Market Value Pitfalls”, Health Care Compliance Association, Dallas, TX, April 18-21, 2010
  • “How to Operationalize Stark and Common Stark Pitfalls”, Inquisit, Nationwide, April 7, 2010
  • “Stark Primer 2 – A Focus on Exceptions”, Inquisit, Nationwide, March 10, 2010
  • “Determining Fair Market Value – Do You Really Need an Appraisal?” AHLA, Miami, FL, February 26, 2010
  • “Stark Primer 1 – Principal Elements of the Stark Law”, Inquisit, Nationwide, February 9, 2010
  • “Stark & Fraud and Abuse for AMCs”, American Bar Association, Nationwide, January 27, 2010 
  • “Employment and Other Alternatives for Physicians”, American Health Lawyers Association Academic Medical Center, Washington, D.C., January 22, 2010

    Past Presentations


Editorial/Advisory Boards

  • Strategies for Health Care Compliance - HCPro Editorial Advisory Board, 2008-present
  • Report on Medicare Compliance Editorial Advisory Board, 2000-pesent

Awards and Recognitions

  • Best Lawyers In America®, Health Care Law, 2009-2014
  • Indiana Super Lawyers, 2009-2014
  • Order of the Coif
  • Omicron Delta Kappa
  • Pi Phi Pi
  • Boy Scouts of America, Distinguished Service Award

Professional Associations

  • American Health Lawyers Association, Member
  • Health Care Compliance Association, Member
  • Holy Cross College, Board of Trustees, 2005-2011
  • Madison Center Hospital, Board of Trustees, 2009-2011
  • Healthwin, Board of Trustees, 2011-present
  • River Valley Community Church, Elder, 1999-2006; Finance Committee, 2006-present
  • Covenant Christian School, 1993-1999; President 1994-1996 and 1998-1999
  • Boy Scouts of America, LaSalle Council, Executive Board, 1993-1997; Friends of Scouting Annual Campaign, Co-Chair, 2000-2011
  • Christmas in April, 1993-1996
  • South Bend Downtown Rotary Club, 1994-2010
  • Junior Irish Soccer Club, Club President, 2008-present; Memorial Day Invitational Tournament, Director, 2005-2008; Tournament Planning Committee, 2005-present
  • Trinity School Fellows, 2003-2007