Compliance:
It's The Season For Giving -- But Not Too Much
Published on Sat Nov 19, 2011
Keep OIG guidance in mind when deciding on your holiday gift list. With reimbursement challenges continuing to plague therapy practices, you may be considering every option you can to generate referrals. But don't let that tempt you into furnishing lavish gifts to your referral sources this holiday season. "Gifts from health care providers to referral sources, patients, vendors and colleagues can create unintentional sticky situations," cautions attorney Patricia Hofstra with Duane Morris in Chicago. "Many businesses give gifts during the holiday season as a token of friendship and appreciation, but for health care providers, the situation is complicated by the Stark laws and the anti-kickback fraud and abuse prohibitions." Providers "should look to avoid any gift giving that could be viewed as inducement to a referral source," experts advise. "The federal government has repeatedly advised that providers should not utilize prohibited or inappropriate conduct (e.g., offer free gifts or services [...]