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CodeMap® Compliance Briefing: 4/29/2011
Editor's Welcome:
Earlier this year, we discussed in detail the Stark Self-Referral Prohibitions and accompanying regulatory exceptions. Today, we will focus on one exception to the Stark Law that offers valuable guidance to providers that perform sales and marketing functions, and/or maintain hospital outreach programs. Many sales representatives take clients to lunch, bring food to referring practices, and/or hand out low value marketing tools such as pens, pads of paper, or other gifts. If your organization routinely performs such sales and marketing functions you must be aware of, and comply with the Non-Monetary Compensation Exception.
Sincerely,
Gregory Root, Esq.
Stark Non-Monetary Compensation Exception
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