Bob Wade
Partner
Suite 1700
Nashville, TN 37203
Bob advises healthcare organizations nationwide on Stark Law compliance, physician compensation structuring, fair market value analysis, commercial reasonableness assessments, self-disclosure strategy, and enforcement defense under the federal physician self-referral statute.
Bob is a nationally recognized Stark Law attorney and one of the leading authorities in the United States on physician self-referral compliance, fair market value, and...
Bob advises healthcare organizations nationwide on Stark Law compliance, physician compensation structuring, fair market value analysis, commercial reasonableness assessments, self-disclosure strategy, and enforcement defense under the federal physician self-referral statute.
Bob is a nationally recognized Stark Law attorney and one of the leading authorities in the United States on physician self-referral compliance, fair market value, and commercial reasonableness. For more than 28 years, he has advised health systems, hospitals, physician groups, and healthcare executives on navigating the Stark Law and related federal fraud and abuse regulations at the highest levels of scrutiny.
Bob focuses his practice on complex Stark Law compliance strategy, government investigations, CMS self-disclosures, Office of Inspector General matters, and Department of Justice enforcement defense. Organizations turn to him when evaluating high-risk financial arrangements, structuring physician compensation models, responding to whistleblower allegations, or defending Stark-based False Claims Act investigations.
He has represented major healthcare providers in investigations before the U.S. Department of Justice and the Office of Inspector General and has led numerous Stark Law self-disclosures to CMS. Most notably, he guided St. Peter’s Health in Helena, Montana, through the investigation and self-disclosure of its financial relationship with Dr. Tom Weiner, culminating in a $10.8 million Settlement Agreement with the DOJ on August 27, 2024- one of the most closely watched Stark matters in recent years.
Bob has also served in significant oversight roles, including as Compliance Expert to the Board of Commissioners under Halifax Health’s Corporate Integrity Agreement, where he helped establish enduring standards for independent CIA compliance oversight.
His perspective is grounded in operational experience. Prior to private practice, Bob served as general counsel and organizational integrity officer for a multi-hospital health system. That experience enables him to deliver Stark Law guidance that is not only legally defensible, but operationally sustainable.
Bob is a frequent national speaker on Stark Law and physician self-referral issues for the American Health Lawyers Association, the Health Care Compliance Association, and other leading industry organizations. He is also the host of Stark Integrity: The Stark Law and Compliance Podcast a nationally followed podcast dedicated exclusively to Stark Law analysis, enforcement trends, compliance strategy, and practical implementation guidance for healthcare leaders.
commercial reasonableness. For more than 28 years, he has advised health systems, hospitals, physician groups, and healthcare executives on navigating the Stark Law and related federal fraud and abuse regulations at the highest levels of scrutiny.
Bob focuses his practice on complex Stark Law compliance strategy, government investigations, CMS self-disclosures, Office of Inspector General matters, and Department of Justice enforcement defense. Organizations turn to him when evaluating high-risk financial arrangements, structuring physician compensation models, responding to whistleblower allegations, or defending Stark-based False Claims Act investigations.
He has represented major healthcare providers in investigations before the U.S. Department of Justice and the Office of Inspector General and has led numerous Stark Law self-disclosures to CMS. Most notably, he guided St. Peter’s Health in Helena, Montana, through the investigation and self-disclosure of its financial relationship with Dr. Tom Weiner, culminating in a $10.8 million Settlement Agreement with the DOJ on August 27, 2024- one of the most closely watched Stark matters in recent years.
Bob has also served in significant oversight roles, including as Compliance Expert to the Board of Commissioners under Halifax Health’s Corporate Integrity Agreement, where he helped establish enduring standards for independent CIA compliance oversight.
His perspective is grounded in operational experience. Prior to private practice, Bob served as general counsel and organizational integrity officer for a multi-hospital health system. That experience enables him to deliver Stark Law guidance that is not only legally defensible, but operationally sustainable.
Bob is a frequent national speaker on Stark Law and physician self-referral issues for the American Health Lawyers Association, the Health Care Compliance Association, and other leading industry organizations. He is also the host of Stark Integrity: The Stark Law and Compliance Podcast a nationally followed podcast dedicated exclusively to Stark Law analysis, enforcement trends, compliance strategy, and practical implementation guidance for healthcare leaders.
Experience
Experience
- Served as lead legal counsel in the internal investigation, self-disclosure, and settlement of the August 2024 $10.8M Settlement with the Department of Justice involving St. Peter’s Health (Helena, Montana) and its employed Medical Oncologist, Dr. Thomas Weiner, under the Stark Law, Civil Monetary Penalties Law, and the False Claims Act
- 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
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
- Tennessee
- U.S. District Court for the Northern District of Indiana
Experience
- Served as lead legal counsel in the internal investigation, self-disclosure, and settlement of the August 2024 $10.8M Settlement with the Department of Justice involving St. Peter’s Health (Helena, Montana) and its employed Medical Oncologist, Dr. Thomas Weiner, under the Stark Law, Civil Monetary Penalties Law, and the False Claims Act
- 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
Media
Recognitions
- The Best Lawyers in America®, Health Care Law (2009–2026)
- 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
Bob advises healthcare organizations nationwide on Stark Law compliance, physician compensation structuring, fair market value analysis, commercial reasonableness assessments, self-disclosure strategy, and enforcement defense under the federal physician self-referral statute.
Bob is a nationally recognized Stark Law attorney and one of the leading authorities in the United States on physician self-referral compliance, fair market value, and... commercial reasonableness. For more than 28 years, he has advised health systems, hospitals, physician groups, and healthcare executives on navigating the Stark Law and related federal fraud and abuse regulations at the highest levels of scrutiny.
Bob focuses his practice on complex Stark Law compliance strategy, government investigations, CMS self-disclosures, Office of Inspector General matters, and Department of Justice enforcement defense. Organizations turn to him when evaluating high-risk financial arrangements, structuring physician compensation models, responding to whistleblower allegations, or defending Stark-based False Claims Act investigations.
He has represented major healthcare providers in investigations before the U.S. Department of Justice and the Office of Inspector General and has led numerous Stark Law self-disclosures to CMS. Most notably, he guided St. Peter’s Health in Helena, Montana, through the investigation and self-disclosure of its financial relationship with Dr. Tom Weiner, culminating in a $10.8 million Settlement Agreement with the DOJ on August 27, 2024- one of the most closely watched Stark matters in recent years.
Bob has also served in significant oversight roles, including as Compliance Expert to the Board of Commissioners under Halifax Health’s Corporate Integrity Agreement, where he helped establish enduring standards for independent CIA compliance oversight.
His perspective is grounded in operational experience. Prior to private practice, Bob served as general counsel and organizational integrity officer for a multi-hospital health system. That experience enables him to deliver Stark Law guidance that is not only legally defensible, but operationally sustainable.
Bob is a frequent national speaker on Stark Law and physician self-referral issues for the American Health Lawyers Association, the Health Care Compliance Association, and other leading industry organizations. He is also the host of Stark Integrity: The Stark Law and Compliance Podcast a nationally followed podcast dedicated exclusively to Stark Law analysis, enforcement trends, compliance strategy, and practical implementation guidance for healthcare leaders.
Experience
The following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.Experience
- Served as lead legal counsel in the internal investigation, self-disclosure, and settlement of the August 2024 $10.8M Settlement with the Department of Justice involving St. Peter’s Health (Helena, Montana) and its employed Medical Oncologist, Dr. Thomas Weiner, under the Stark Law, Civil Monetary Penalties Law, and the False Claims Act
- 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
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
- Tennessee
- U.S. District Court for the Northern District of Indiana
Practice Areas
- The Best Lawyers in America®, Health Care Law (2009–2026)
- Indiana Super Lawyers, Healthcare, 2009-2022
- 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
- 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
Highlights from the Firm’s Insights
