Compliance Policy/Procedure Bribes, Kickbacks, and Gratuities _________________________________________________________________________________________ _
Policy: No executive, administrator, manager or employee will accept a bribe, kickback or major gratuity from any source at any time. Procedures: 1. A bribe is defined as any payment or gift which is outside the normal course of business and which is intended to influence patient care, such as determining admissions, selection of allied providers, selection of vendors, selection of pharmaceuticals, or which is intended to influence purchasing, contracting, hiring, etc. 2. A kickback is defined as a return of a portion of any payment which is outside the normal course of business, whether to the facility, directly to an employee or executive, offering of discounts not in the ordinary course of business, etc. 3. A major gratuity is defined as a substantial gift of goods, services or money which, although not tied to a specific transaction or contract, is intended to influence the decision making of the recipient with regard to patient care, contracting or purchasing. The acceptance of de minimus gratuities is acceptable (e.g., candy and cookies, small holiday gifts of less than $50, calendars and pens, etc.) as long as such gratuities are logged with [_______________]. 4. Any offer of a bribe, kickback or major gratuity by anyone should be reported immediately to [_________________________], with any documentary evidence available. Any such offer should be politely refused, citing this company policy. 5. The Board, working with legal counsel, will be the final arbiter of what constitutes a bribe, kickback or major gratuity. 6.
The Board, working with legal counsel, will determine if any offered and/or accepted bribe, kickback or major gratuity should be reported to authorities.
7. The acceptance of a bribe, kickback or a major gratuity in violation of this policy, and/or the attempt to hide any such receipt in order to evade review pursuant to this policy will be subject to discipline.
Date Approved:____________________________________ Effective Date:___________________________________ Date Amended:_____________________________________ Date Revoked:___________________________________
Compliance Policy/Procedure Bribes, Kickbacks, and Gratuities _________________________________________________________________________________________ _
Date Approved:____________________________________ Effective Date:___________________________________ Date Amended:_____________________________________ Date Revoked:___________________________________