The Compliance Minute

In this month’s installment of “The Compliance Minute” we are focusing on Gifts – Giving and Receiving.  As we continue through the holiday season, many of us may be the giver or recipient of a gift.  It’s important to understand our policy on this and when and how gifts may be considered inappropriate and or violate any federal health care rules. 

In general, most gifts we give or receive during the holiday season will be appropriate and not seen as a concern.  Giving a pumpkin pie at Thanksgiving to a physician to say thank you for all they do will not violate any remuneration laws.  But if we give a physician a brand-new flat screen TV in hopes they may increase their referral volume to us – this could be seen as a violation of our policy and applicable laws and rules. 

Likewise, it’s typically fine to receive a gift basket from a resident/family if the gift basket is provided to all of the team members at the facility.  A team member who receives/accepts/keeps a gift basket (or other gift) solely for themselves may be in violation of our policy.  Should you be the recipient of a gift, the employee is to notify their immediate supervisor promptly.  The acceptance of gift by a staff member may cause the facility to receive a citation at F602 – Misappropriation and Exploitation. 

Facility leaders are encouraged to communicate this policy to residents and their families.  An alternative to gifts for specific employees would be to provide an expression of thanks to the whole facility- trays of cookies, fruit baskets, etc. would be most appreciated. 

Employees wishing to learn more about the Gifts policy should refer to the Gift policy located on SharePoint, and/or review page 9 of the Code of Conduct.  Additionally, employees may speak with their administrator or contact me at [email protected] or at 248-940-5390, ext. 1023. 

Wishing you and yours a safe and joyous holiday season.

Contact Information:

Emery Dumas, LNHA, CHC
[email protected]
“We Care” Hotline: 616-975-5335 or [email protected] (may remain anonymous)