Revenue Cycle Insider

Thread the needle on prizes that are fun for kids, tolerable for adults, and compliant with state and federal regulations.

Many doctors’ offices, especially those with pediatric patients, keep a box or chest full of small toys, stickers, or other incentives to reward or soothe children after an appointment.

Prize boxes are common and seemingly innocuous, but they may still cause issues with compliance or contagion. Find out more about how to have a safe and compliant prize box in your office.

Know How Toys Are Transitional Objects

Psychologist Donald Winnicott theorized that toys are transitional objects. His studies suggested that a child having an object to touch helps facilitate the natural (but possibly emotional) separation of parent and child, specifically mother and infant, as the child grows.

The same concept applies to the doctor’s office prize box: A child who is feeling sick or upset after receiving vaccinations has something to look forward to and an object to take home and keep. The object in question, even an inexpensive, small toy, can be soothing for the child and help them transition from the end of an encounter to the next part of their day.

Be Careful of Compliance

There are some aspects of compliance to keep in mind for prize boxes. Practices that accept Medicare or Medicaid and have prize boxes need to keep Stark Law and the anti-kickback statute in mind.

The anti-kickback statute prohibits the exchange (or offer to exchange) of anything of value to induce or reward the referral of federal health care program business.

The Stark Law prohibits a physician from referring patients to receive “designated health services” payable by Medicare or Medicaid from entities with which the physician or an immediate family member has a financial relationship, unless an exception applies.

In terms of gifts to patients, these laws generally mean that healthcare providers cannot offer gifts to patients in exchange for their business or referrals. The Office of Inspector General (OIG) has stated that inexpensive gifts of nominal value (under $15 per item or $75 in the aggregate per patient per year) are permissible. However, cash or cash equivalents, like gift cards, regardless of the amount, cannot be given as they could be construed as a kickback.

It’s also important to note that state laws may also have rules about gifts to patients, and these can vary widely. Therefore, it’s always a good idea to consult with a healthcare attorney or compliance expert to ensure you’re following all applicable laws and regulations.

Remember to Consider Safety

If your office sees pediatric patients and you have a prize box, you need to be sure that the items in the prize box are appropriate and safe; also, make sure that the prize box itself doesn’t become a hotbed of germs.

There are different ways to mitigate the risk. While offering inexpensive candy like a lollipop used to be de rigueur, many practice managers have moved toward toys or stickers instead. Having prizes that don’t have small parts and thus do not present a choking hazard is important, and choosing prize options that don’t have sugar, since childhood obesity is on the rise, may feel like practicing what providers preach. Regardless, you should feel like the prizes you offer are enticing to children without being off-putting to adults. For example, parents on social media forums decry that doctors’ and dentists’ offices have become another source of cheap plastic toys and their annoyance with stickers that end up plastered to the insides of their washers or dryers or on their furniture or floors.

Finding a happy medium of prizes that the practice can afford (and that are compliant with anti-kickback statute rules), children want, and adults can tolerate may be a major undertaking involving trial and error. Social media platforms like Reddit feature conversations by practice staff and patients about the pros and cons of various prizes.

Contagion is another element to manage. One way to avoid germy hands sorting through prizes is to have examples of what’s available and let a child choose which they want by pointing to the example. You could have individually wrapped prizes if you aren’t concerned about additional waste — or have a policy where people who access prizes wash their hands beforehand.

Prize boxes can be a highlight for children or other patients after an encounter with a provider, but you need to make sure they don’t cause any headaches!

Rachel Dorrell, MA, MS, CPC-A, CPPM, Production Editor, AAPC