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RE: policy and procedure manual

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Hi, -

You may contact Angie at images@... . She has been

doing Rehab oriented P & P Manuals with crosswalks for some time. It doesn't

get much better.

Dick Hillyer, DPT

Dr. Hillyer, PT, DPT, MBA, MSM

Hillyer Consulting

Cape Coral, FL 33914

_____

From: PTManager [mailto:PTManager ] On Behalf

Of Nicolle s

Sent: Monday, April 04, 2011 7:34 PM

To: ptmanager

Subject: policy and procedure manual

I'm looking for downloadable or website based policy and procedure manual

that can be easily customizable. I tried the product from MCN, but was

highly disappointed. Anyone have any great therapy based resources? Thank

you~

Nicolle s, PT, MSPT, CLT-LANA, CWS, CKTP

Director of Rehabilitation Services

Hegg Memorial Health Center

Rock Valley, IA

To: PTManager <mailto:PTManager%40yahoogroups.com>

From: bperlson@... <mailto:bperlson%40asante.org>

Date: Mon, 4 Apr 2011 16:44:10 +0000

Subject: RE: Marketing to Physicians

I find this thread fascinating, especially since our organization enforces a

collective annual " gifts policy " that cannot exceed $50 per physician. There

are some exceptions for group lunches and so forth, but basically it has to

pass the smell test.

Check out CMS' language (I'm not positive this is the most up-to-date):

" Among its provisions, the anti-kickback statute penalizes anyone

who knowingly and willfully solicits, receives, offers or pays

remuneration in cash or in kind to induce, or in return for:

A. Referring an individual to a person for the furnishing, or

arranging for the furnishing, of any item or service payable under the

Medicare or Medicaid program; or

B. Purchasing, leasing or ordering , or arranging for or

recommending purchasing, leasing or ordering, any goods, facility,

service or item payable under the Medicare or Medicaid program.

Violators are subject to criminal penalties, or exclusion from

participation in the Medicare and Medicaid programs, or both. "

The AMA has it's own ethics guidelines: See

http://www.ama-assn.org/ama1/pub/upload/mm/437/ama_m4_ph.pdf

Most of the regulation is aimed at device and drug manufacturers, but

certainly could apply to physicians and/or therapy practices who have

developed referral relationships based on what the therapy practice does for

the physician practice.

Trust your nose.

Bob Perlson

Director, Rehabilitation Service

Rogue Valley Medical Center

Medford, OR

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