Ensure marketing doesn’t trigger fraud accusations
All home health managers have heard that they should market to referral sources to build their referral base. How to market without triggering accusations of "buying referrals" is the tricky part, says Denise Bonn, JD, counsel for Schmeltzer, Aptaker & Shepard, a Washington, DC, law firm with specialists in home health.
"Basically, you can’t pay for referrals," she says. While most home health managers know this, be careful that you don’t appear to be paying for these referrals in more subtle ways than handing cash to the referral sources, Bonn points out.
"If you are paying a physician for something such as space rental for one of your locations, make sure you are paying no more than fair-market value for the space. Anything over fair-market value can be construed to be payment for referrals the physician may send your agency," she adds.
While wining and dining good customers or referral sources is standard operating procedure for most industries, it is a no-no for home health, Bonn says. Don’t underwrite the hospital discharge planning department’s holiday party or pay for a physician’s office staff luncheon if you don’t want to appear that you’re buying referrals, she adds.
Presenting seminars that focus on services, new wound care techniques, or expansion of service areas or hours are appropriate for home health agencies to present to physicians’ office staffs or hospital discharge planning staffs as part of their need for continuing education, but don’t plan to serve a large meal with the seminar, Bonn suggests.
"Although you might be able to defend your expenditure on the meal, why put yourself in a defensive position?" she asks.
All home health managers have heard that they should market to referral sources to build their referral base. How to market without triggering accusations of buying referrals is the tricky part, says Denise Bonn, JD, counsel for Schmeltzer, Aptaker & Shepard, a Washington, DC, law firm with specialists in home health.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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