Practice areas
Six areas of focus. Each one is handled by Bob directly, for hospitals, health systems, physician groups and healthcare executives nationwide.
The core of the practice. Bob analyzes financial relationships between hospitals and referring physicians against the Stark Law's exceptions, structures arrangements to fit them, and remediates the ones that do not.
Where the Stark Law is strict liability, the Anti-Kickback Statute turns on intent. Bob structures referral-source relationships to fit a safe harbor where one exists and documents the risk analysis where one does not.
Stark and Anti-Kickback problems become False Claims Act problems. Bob represents providers responding to the Department of Justice and qui tam relators, from the first civil investigative demand through settlement.
An arrangement is only as safe as the file behind it. Bob evaluates whether compensation is fair market value and commercially reasonable, and builds the record a reviewer would need to agree.
Bob has led numerous Stark Law self-disclosures to CMS and self-reports under the OIG protocol, including one of the most closely watched Stark self-disclosures in recent years. He advises on whether, when and how to disclose.
Bob has served as independent compliance advisor to a hospital board under a five-year Corporate Integrity Agreement. He reviews programs for effectiveness and turns findings into recommendations a board can act on.
Describe the arrangement. Bob will tell you where it sits.
