Integrity Standards Handbook - Penrose-St. Francis

Anti-Kickback and Anti-Competition (Antitrust)You are prohibited from soliciting, accepting or offering anything ofvalue in exchange for patient referrals. Physicians are prohibited frommaking a referral to any entity in which they or their immediate family membershave a financial relationship, unless approved by Centura’s CorporateResponsibility Department and/or Legal Department. Laws and regulatoryrestrictions in this area are complex; you should contact the Legal Departmentwhen any uncertainty exists. Also see Centura’s Frequently Asked Questionson Gifts From Business Sources and the Stark Self-Referral Statute foradditional information.In addition, you must comply with applicable laws that regulate competition,including antitrust. Under no circumstances may you exchange competitivelysensitive information with our competitors, vendors or other business associates.Examples of conduct prohibited by these laws include 1) agreements tofix prices, bid tampering, and collusion with competitors; 2) boycotts and certainexclusive dealing arrangements; and 3) unfair trade practices includingbribery, deception and intimidation. You are expected to seek advice fromCentura’s Corporate Responsibility Department or Legal Department whenconfronted with business decisions involving a risk of violation of these lawsor when clarification of these laws is needed.You are prohibited from offering anything of value or enticing patients, residentsor other individuals to use or purchase an item or service for whichMedicare or Medicaid pays. You are encouraged to contact the CenturaCorporate Responsibility Department or Legal Department with any questions,clarifications or concerns involving this matter.Q:A:What are “kickbacks” or “incentives for referrals”?Giving or receiving gifts, gratuities or anything of value to or fromsomeone who refers an individual, or is in a position to influencereferrals in any way, may constitute a kickback. Examples of kickbacksinclude offering excessive discounts to patients, providing suppliesor equipment free of charge, offering gifts to individuals toobtain their business, writing-off accounts receivable without followingthe guidelines established by policy, offering professional courtesiesto physicians to encourage them to refer their patients to ourfacility, and leasing office space at less than fair market value. Foradditional guidance see Guidelines for the Insured/Uninsured,Policy on Prompt Pay Discounts and Policy on Charity Care.11