Compliance Corner

By Robin Brown, Chief Compliance Officer
REMINDER: Gift Policy During the Holiday Season

Occasionally, vendors and other business associates want to provide EHS staff with gifts, particularly during the holiday season. However, appreciative of these kind thoughts, the EHS Code of Conduct has strict guidelines on EHS’s gift policies, especially those involving people and organizations we do business with. The rules about gifts are necessary to ensure independence in business judgment.

Please refer to the Code of Conduct for full details involving gifts. Some of the most common rules that we must follow are below. If you still have questions, contact the Compliance Officer for additional guidance.:

Gifts from Our Organization to Physicians and Other Referral Sources: EHS never offers gifts to physicians or other referral sources in exchange for patient referrals or any other business. Limited gifts to physicians and other referral sources that are not cash or cash equivalents must be given in compliance with federal and state laws and organizational policies. All applicable provisions of the Physician Referrals Stark Law Compliance Policy, Business Courtesies to Physicians and Immediate Family Members Policy, and Anti-Kickback Compliance Policy must be met before offering gifts to physicians or other referral sources. When giving gifts to physicians, you must notify the Administration so that the gift can be logged. There are annual limits that we must abide by.

Gifts from Physicians and Other Referral Sources to Our Organization: EHS never accepts gifts from physicians or other referral sources in exchange for patient referrals or any other business.

Gifts from “Industry” and Other Vendors to Us Personally: There are significant ethical limitations regarding accepting personal gifts from “Industry” and other vendors. “Industry” vendors are pharmaceutical, biotech, medical device, equipment, or supply companies or organizations. We do not accept personal gifts from “Industry” vendors. For “Industry” vendors, we do not accept cash, cash equivalents, or gift cards offered to us personally. We may accept items of modest value from “Industry” vendors, such as food or flowers, provided the gift is shared with our entire department or unit. All applicable provisions of our policies must be met before accepting gifts from “Industry” or other vendors.

Gifts from Industry and Other Vendors to Our Organization: EHS never accepts gifts from “Industry” or other vendors in exchange for any business.

Compliance Corner

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