tci Outpatient Facility Coding Alert - 2018 Issue 3
Reader Question: Delve Into Nuances of CMPL
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Article Overview
This Q&A-style article discusses how the Civil Monetary Penalties Law affects the offering of free or discounted items and services in an ASC setting. It is aimed at compliance, billing, and administrative readers who need a high-level understanding of marketing-related restrictions, limited exceptions, and the kinds of internal policies and safeguards that may be relevant when evaluating complimentary benefits for patients.
Why This Topic Matters
Complimentary items and services can create compliance risk if they are viewed as inducements or inconsistent with applicable exceptions. This article helps readers identify the general compliance issues that may affect patient-facing offers and internal policies in an ambulatory surgery center.
What You Will Learn
- How the Civil Monetary Penalties Law relates to complimentary items and services in an ASC
- What broad compliance concerns arise when discounts, waivers, transportation, or gifts are offered to patients
- What types of general safeguards and policy considerations may be relevant in this setting
- How preventive screenings and related patient outreach are discussed at a high level in the article
Who Should Read This
- ASC administrators
- Compliance officers
- Billing and reimbursement staff
- Healthcare attorneys
- Practice managers
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