Kickbacks:
Beware Pitfalls In Furnishing Bridge Services
Published on Thu Dec 06, 2012
Follow these 5 steps to compliance. If you want to protect your free services program by following the hospice's example in the OIG's latest advisory opinion, there are some important rules you should follow. 1. Delineate services. A big reason the HHS Office of Inspector General approved the hospice's request for a free bridge program (see story, p. 332) is because it offered low-monetary-value services provided by volunteers, hospice legal experts point out. Don't just assume you can water down your regular hospice services. The "OIG has stressed that the program must be for volunteered services ... of a non-skilled, non-homecare or hospice-like content," counsels attorney Deborah Randall with Deborah Randall Consulting in Washington, D.C. The programs the OIG has approved are "fundamentally a friendly visitor/companion type service with some shopping and transportation," she tells Eli. Bottom line: Do not include any professional or paraprofessional services, Randall advises. 2. Eschew [...]