Fast Break: Holiday Gifts

It's that time of year again . . . gift-giving season! Unfortunately, unlike virtually all other industries, gifts to colleagues, employees, referral sources, or even patients can expose healthcare entities to risk. While the Office of the Inspector General (OIG) has increased the nominal gifts amount for beneficiary inducement purposes, the Stark Law has a strict nonmonetary compensation threshold and the Anti-Kickback Statute (AKS) has no de minimis exception at all. Join us for our next Fast Break to discuss some of the ways that healthcare entities can avoid or mitigate potential liability while embracing the holiday spirit.

Topics will include:

• Background of Stark Law, AKS, and the beneficiary inducements CMP 
• "One-purpose test" considerations 
• To gift or not to gift? 
• Tips to manage remuneration to referral sources