Do you have a policy/procedure? Our compliance program states, in part (de-sanitized):
BUSINESS RELATIONSHIPS: BUSINESS TRANSACTIONS WITH VENDORS, CONTRACTORS AND OTHER THIRD PARTIES SHALL BE TRANSACTED FREE FROM OFFERS OR SOLICITATION OF GIFTS AND FAVORS OR OTHER IMPROPER INDUCEMENTS IN EXCHANGE FOR INFLUENCE OR ASSISTANCE IN A TRANSACTION.
The Standards set forth below are intended to guide key employees in determining the appropriateness of the listed activities or behaviors within the context of Hospital business relationships, including relationships with vendors, providers, contractors, third party payors and government entities. It is the intent of Hospital that this policy be construed broadly to avoid even the appearance of improper activity. If there is any doubt or concern about whether specific conduct or activities are ethical or otherwise appropriate, you should contact your supervisor, Hospital's legal counsel, or the Corporate Compliance & Privacy Officer.
Gifts and Gratuities. It is Hospital's desire to at all times preserve and protect its reputation and to avoid the appearance of impropriety. Consequently, the following standards shall be followed.
(a) Gifts from Patients or Families. Employees are prohibited from soliciting or accepting tips, personal gratuities or gifts from patients or their families. If an employee is offered a gratuity or other gift, the employee may direct patients and their families to Hospital's Foundation Office to make a charitable donation to the System.
(b) Gifts Influencing Decision-Making. Employees shall not accept gifts, favors, services, entertainment or other things of value to the extent that decision-making or actions affecting Hospital might be influenced. Similarly, the offer or giving of money, services or other things of value with the expectation of influencing the judgment or decision-making process of any purchaser, supplier, customer, government official or other person by Hospital is absolutely prohibited. Any such conduct must be reported immediately either to a supervisor, Hospital's legal counsel, or the Corporate Compliance & Privacy Officer.
(c) Gifts From Existing Vendors. Employees may accept and retain gifts from vendors which have a nominal value. Hospital has made no attempt to define "nominal" as a specific dollar value. Rather, Hospital expects its employees to exercise good judgment and discretion in accepting gifts. If an employee has any concern whether a gift should be accepted, the employee should consult with his/her supervisor. To the extent possible, these gifts should be shared with the employees' co-workers. Employees shall not accept excessive gifts, meals, expensive entertainment or other offers of goods or services which have more than a nominal value nor may they solicit gifts from vendors, suppliers, contractors or other persons.
(d) Vendor Sponsored Entertainment. At a vendor's invitation, an individual may accept meals or refreshments of a reasonable value at the vendor's expense. Occasional attendance at a local theater or sporting event, or similar entertainment of reasonable value at vendor expense, may also be accepted, provided that a regular business representative of the vendor is in attendance with the employee.
Workshops, seminars and training sessions. Attendance at local, vendor-sponsored workshops, seminars and training sessions is permitted. Attendance, at vendor expense, at out of town seminars, workshops and training sessions is permitted only with the approval of the President and CEO.
Thank you!
Cinda
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