Q&A: Gifts between physicians and providers
Compliance Monitor, February 4, 2009
Q: Can a gift exchange between physicians and providers lead to a Stark violation?
A: Yes. Gifts and benefits exchanged between physicians and providers can lead to Stark Law violations if they are not monitored.
Providers should track and monitor each financial arrangement and all gifts and benefits, including dinners at restaurants and tickets to sporting and other entertainment events.
Such scrutiny is necessary to ensure that no referring physician receives more than the $338 limit of gifts and benefits during the year. This amount will be subject to the Consumer Price Index for All Urban Consumers increase for this year. If you find that your facility has surpassed that limit, regardless of whether it was intentional, you must disclose the information.
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