RE: Marketing to Physicians

[Guest guest]

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