Chief Compliance and Ethics Officer Health Care

Oncology Wellness Services

  • 1.  Oncology Wellness Services

    Posted 06-02-2020 10:44 AM
    ​I am hoping for input re how to offer ancillary services to oncology related wellness programs.   By ancillary services, I mean things like acupuncture (that Medicare does not reimburse for), social worker counseling/support, strengthening classes (e.g., Pilates, yoga, etc.), cooling caps (yes, really), nutritional counseling or cooking classes, etc.  Most, perhaps all but the cooling caps, of the services are required for Commission on Cancer certification, so these are not unique services.  Our wellness program folks are concerned that patients will not utilize the services if we charge for the services, so the folks would like to offer the services either free, or at steeply discounted cash pricing.   The folks have researched, and found that other cancer programs offer these services at discounts, and even advertise the discount pricing.   This seems contrary to AKS prohibitions against patient inducement by offering gifts or items of value greater than $15 per gift or $75 annually.

    When I say "no" we can't offer these for free, I get a lot of pushback because "everybody else is doing it."

    Any help with a compliant way that I can say "yes" will be appreciated.

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    Scot Houska
    Chief Compliance Officer / Privacy Officer
    Community Hospital
    Grand Junction,CO
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    19th Annual CEI Virtual Conference


  • 2.  RE: Oncology Wellness Services

    Posted 06-03-2020 07:19 AM
    ​Good Morning -

    We are also struggling with this and I also have red flags waiving for free or reduced cost services in terms of Anti-kickback and the Civil Monetary Penalties. In the past the OIG has said if 'appropriately structured' ( and I don't  know what that exactly means), programs that provide community and/or patient benefit even though not meeting an exception can be OK. So, I believe it depends on the amount of risk your organization is willing to take.

    I don't have any good answers for you and hope others will be able to help both of us!

    I do have to add that my response to  the comment that "everyone else is doing it" is 1.  who is everyone else and 2.  'just because they are doing it doesn't make it right'.

    Have a good Wednesday!

    Jan

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    Jan Walton
    Director, Corporate Compliance
    Oaklawn Hospital
    Marshall,MI

    jwalton@oaklawnhospital.com
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    19th Annual CEI Virtual Conference