Multi-Industry Chief Compliance and Ethics Officers

  • 1.  Gift Giving/Receiving

    Posted 10-17-2022 08:37 AM
    Hello All,

    I have two questions regarding gift giving and receiving.

    Background: I am a CO for a small, non-profit HCBS waiver service provider in NY. We provide Day Habilitation and Employment services for individuals with intellectual and developmental disabilities and are funded mainly by Medicaid.

    1. We have an individual that we support that is in the hospital. A group of our employees wanted to chip in and get her mother a coffee gift card. Is this allowed, and are there any rules or thresholds to be aware of?

    2. I just found out that a family of a person that is enrolled in services here has gifted our agency high-dollar items in the past (trailer, snowmobile, etc.). This person has a special privilege as he is allowed to be dropped off at our office daily rather than be picked up by staff. This privilege is purely coincidental as he lives outside of our service area, and we do not have the resources to travel to his home. I think that it could look bad for us, however. Are the gifts allowed by families or would this violate federal laws?

    Thank you al for your help.

    Dennis Hulett
    Corporate Compliance & Privacy Officer
    LifeSong, Inc
    Clifton Park,NY
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