To Give or Not to Give – That is THE [Compliance] Question

Remember the good ole’ days when sales reps, particularly in pharmaceuticals, had unlimited budgets to entertain their clients? Golf outings, dinners for physicians and lunches for office staffs were only a few of the norms in an attempt to recognize or gain business. This is not the case anymore. In addition to budgets restraints, many provider offices will no longer accept anything from anyone – gadgets or food.

Kim Grant shares best practices for navigating the ever-changing interpretations of compliance.

This is actually a good thing for physician liaisons. Why you ask? Because somewhere along the way gifts and office lunches became commonplace – even expected! As a physician liaison representing your hospital, you must position yourself as a trusted advisor and resource for information and feedback about hospital policy and activities relevant to them and their patients.

As a former liaison, Kim used limited resources to provide valuable and relevant tools for the providers. Those tools included order forms, scheduling calendars, directories, maps, and health information for them and their patients. Her offices never expected food or goodies but rather came to depend on these tools and her expertise to help them with patient care, education, and access.
So does that mean we can never bring them anything special or fun? Not necessarily. But in today’s regulatory environment, we have to be careful about what we give to physicians and how we use any dollars to interact with a physicians and their office staffs. Compliance officers at every hospital need to be the liaison’s best friend. Liaisons kneed to know what they can and can’t do as it relates to Stark, Anti-Kickback, and other compliance regulations.
Having said that, we at Tiller-Hewitt HealthCare Strategies thought it might be interesting for our readers to share how you and your organizations navigate the ever-changing interpretations of compliance. Please answer the following questions and submit them to us at ksg@tillerhewitt.com. We will compile the answers and post the results in our July blog.

1. As a Liaison, did you have any formal or informal compliance training specifically related to Stark and/or Anti-Kickback Statutes?
2. Are you aware there is an annual non-monetary compensation limit per physician?
3. If you are aware there is a limit, do you know the dollar limit amount?
4. In your organization, do you have a formalized way of tracking the amount spent on physicians?
5. Who is the keeper of that information within your organization?
6. If you do track, what types of things (food, goodies, etc.) are you required to track?

We look forward to hearing from you.