5. Helping out poor patients with food or food coupons. This could be a kickback, even though it seems like harmless charity. A well-intended act of generosity could come back to haunt you because regulators are always wary of your motives.
"From the state's perspective, they know that some people don't do these things out of goodwill but because they think it encourages the patient to come back to their office instead of going somewhere else for care," Dagli says. "It's unfortunate that you have to think about that when you're just trying to be a good guy by giving them food or a gift card, but it is something that the state is going to look at and possibly misinterpret."
The guidelines for such gifts state that, in general, a single gift worth $10 or less, or an aggregate of $50 in one year, will not be considered an inducement, Dagli explains. Keeping track of the free doughnuts and hamburger coupons you hand out may not be worth the trouble, but Dagli says regulators will be more attuned to a systematic program that seems to reward patients for their business.
"Any program in which you offer some kind of gift for visiting regularly will get you into trouble, even if your real goal is just to encourage people with chronic conditions to come in for checkups," he explains.