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Referrals, Kickbacks, Patient Inducements, and Marketing

Forbids paying or receiving anything of value for referrals, sets the conditions for any financial arrangement with physicians and other referral sources, limits gifts to patients, and requires all marketing to be accurate and limited to services the Agency is licensed for and provides.

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About this policy
Policy number
OH-HH-ETH-02
Version
1.0
Main rule
42 U.S.C. §1320a-7b(b)
Library
Ohio home health · 59 policies
Category
Ethics
Sections
16

In short

  • Never offer or accept money, gifts or favors for referrals.
  • Never give cash or gift cards to patients or referral sources.
  • Patients are always free to choose their home health agency.
  • Describe only the services we really provide, in the counties we serve.
  • Report any offer of a kickback to the Administrator.

What's inside

16 sections. The full text comes with the One-time Policy Pack.

Full text with a package
  • Terms of Reference
  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Policy Statement (42 U.S.C. §1320a-7b(b))
  • 5. Arrangements With Referral Sources
  • 6. Gifts and Hospitality
  • 7. Patients
  • 8. Marketing and Public Information
  • 9. Responsibilities
  • 10. Records and Compliance Monitoring
  • 11. Staff Training
  • 12. References
  • 13. Related Policies and Forms
  • 14. Approval
  • 15. Revision History

An inspector may ask

  • Do you pay anyone for referrals or give gifts to physicians, discharge planners or facilities?
  • Show me your written agreements with any physician or referral source and how the payments were set.

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