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.
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:
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:
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)
Thank you for sharing this, Wendy, I think you worded it very nicely!
Brenda Tuohey, CHC
Sr. Compliance Specialist
Health Services Compliance
Please note: My email address has recently changed to Brenda.Tuohey@hf.org. Please update your records accordingly.