Communication Training and Curriculum Development

Gifting Policy Communication

  • 1.  Gifting Policy Communication

    Posted 10-31-2019 02:27 PM
    With the holidays quickly approaching, many providers may have questions about acceptable gifts from patients or vendors.  We are thinking of ways that we can easily communicate this information to our providers during the holiday season.  What are some ways that you all communicate quick gifting education to your providers or employees during the holiday season?  We were thinking about sending out a gifting one pager via our health system email communications.

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    Danique Flax
    Compliance Manager
    VCU Health
    Richmond,VA
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    2020 SCCE Membership


  • 2.  RE: Gifting Policy Communication

    Posted 11-01-2019 03:45 PM
    Edited by Wendy Smith 11-01-2019 03:45 PM

    I did an email blast last year to all leadership with the following message:

    The Season of Gift Giving is upon us and while we are always grateful for gifts from vendors, patients and/or their families, we must also avoid circumstances in which the acceptance of gifts could result in improper influence, or give the appearance of improper influence upon business decisions made on behalf of AnMed Health. We must also ensure that by accepting a gift, that we do not create an obligation to the patient, family member or vendor.

    Info

    Gift giving and receiving should be made in accordance with our Code of Conduct and Conflict of Interest Policy. Some examples of best practices are listed below:

    1. AnMed Health employees may never accept cash or cash equivalents, (e.g., gift certificates, checks or stocks).
    2. AnMed Health employees should never solicit a gift under any circumstances.
    3. Perishable or consumable gifts (flowers, baked goods, candy) received should not be lavish and may be shared within a department or group.

    Before providing a gift to a physician who refers patients to the hospital (including employed physicians), make sure you aren't inadvertently violating the laws on non-monetary compensation to physicians.

    What is "Non-monetary Compensation"?

    Non-monetary compensation can be any non-cash item or service provided to a referring physician or the physician's immediate family member. Some examples include but are not limited to:

    1. Meals, cocktail hours, or parties.
    2. Tickets to events.
    3. Holiday gifts and or other gifts.

    AnMed Health may pay for occasional meals, entertainment and gifts to physicians, as long as the total annual value of all that fun stuff for any one physician doesn't go over the cap set by the federal government. The cap for 2018 is $407. Remember it's not just your planned activity that counts toward the cap. The physician may already be close to the limit. So before you send an invitation or buy those physician gifts, complete the Physician Non-Monetary Compensation log in the Midas Database. (Physician Non-Monetary Compensation Policy attached)



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    Wendy Smith
    Director of Compliance and Privacy Officer
    AnMed Health
    SC
    wendy.wright@anmedhealth.org
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    2020 SCCE Membership


  • 3.  RE: Gifting Policy Communication

    Posted 11-04-2019 07:55 AM

    Thank you for sharing this, Wendy, I think you worded it very nicely!

     

    Brenda

     

     

    Brenda Tuohey, CHC

    Sr. Compliance Specialist

    Health Services Compliance

    Office:  321.434.7532

    Cell:  321.427.5438

    Brenda.Tuohey@HF.org

    HF.org

     

     

    Please note: My email address has recently changed to Brenda.Tuohey@hf.org.  Please update your records accordingly.

     

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    2020 SCCE Membership


  • 4.  RE: Gifting Policy Communication

    Posted 11-04-2019 09:17 AM
    Thank you for sharing Wendy! This is very helpful!​

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    Danique Flax
    Compliance Manager
    VCU Health
    Richmond,VA
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    2020 SCCE Membership


  • 5.  RE: Gifting Policy Communication

    Posted 11-04-2019 03:01 PM
    The $407 is an interesting amount Wendy. What went into deciding that amount?

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    Carl Russell
    Compliance Analyst, CHPC
    Delta Dental of Idaho
    Boise,ID

    Anything I say is my sole opinion and not of my company.
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    2020 SCCE Membership