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 episodes, “Not All wRVUs are Created Equal (Part 1), and “Part 2,” examining the role of work relative value units (wRVUs) and fair market value (FMV) in physician compensation under the Stark Law. The episodes are part of the Let’s Talk Compliance partnership between PYA and Foley & Lardner.
In Part 1, 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.
In Part 2, Caldwell and Kolarik provide best practices with FMV and wRVUs. For compensation reviews, Caldwell emphasizes clear policies, defined internal review tiers, and defined annual reviews to ensure compensation remains within fair market value. She notes that FMV is a range, not a formula, and that when problems arise, organizations should pause to verify the data and address both the arrangement and any systemic issues.
They discuss that compensation must align with how physicians work, and data should maintain trust and compliance. Kolarik adds that FMV is not “set it and forget it,” stressing ongoing monitoring, transparency, and contract provisions like reconciliation or “clawbacks” are essential to maintaining compliance and avoiding regulatory risk.
| Listen to Part 1 of the podcast |
| Listen to Part 2 of the podcast |
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.
PYA’s experts are committed to serving the healthcare industry with expertise in compliance, regulatory requirements, strategy, and transactions.
