Angie Caldwell, PYA Principal and Chief Financial Officer, and Jana Kolarik, a Partner in Foley & Lardner’s Health Care Practice Group, are featured in a recent Let’s Talk Compliance podcast episode, “Not All wRVUs are Created Equal (Part 1),” examining the role of work relative value units (wRVUs) and fair market value (FMV) in physician compensation under the Stark Law. The episode is part of the Let’s Talk Compliance partnership between PYA and Foley & Lardner.
The discussion focuses on how productivity-based compensation models can create compliance risk if wRVUs are not calculated and applied accurately. Caldwell and Kolarik note that because an estimated 70% of hospital-employed physicians are paid at least in part based on wRVUs, the integrity of wRVU data is critical.
They also discuss the close connection of compliance, billing integrity, and compensation and the distinction between services billed under a physician’s National Provider Identifier (NPI) and services personally performed by the physician.
The speakers caution against overextending the wRVU framework, and Caldwell warns that creating “proxy” wRVUs for administrative services or forcing productivity-based models onto hospital-based specialties can introduce unintended incentives.
The episode also addresses common misconceptions around FMV.
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The Let’s Talk Compliance podcast series is for healthcare leaders and compliance professionals, as well as providers, suppliers, vendors, and others in the healthcare industry. In each episode, a Foley & Lardner attorney and a PYA advisor discuss a trending compliance topic and address questions they hear most often from clients.
The podcast is part of Foley & Lardner’s Health Care Law Today series. Listeners can subscribe to both series on Apple Podcasts, Spotify, or their preferred podcast app. All episodes of Let’s Talk Compliance podcasts and webinars can also be found on the PYA website.
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