tci Medicare Compliance & Reimbursement - 2011 Issue 2

What Do You Think?: How Would Your Practice Handle This Scenario Involving a Free Med Sample?

Just because you provide a sample as part of care during a visit doesn't mean compliance concerns don't apply. Question: What should a physician practice consider when providing free samples of a medication in conjunction with an office visit procedure? The nurse administers the medication as part of the care during the visit.Answer: For starters, the practice should not bill the patient or any payer for the medication, advises attorney Chris DeMeo, in Houston, Texas. And "don't use the samples as a way to induce patients to the practice." For example, you wouldn't advertise or promote the...

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