Saint Joseph Health System Corporate Identity and Graphic ...

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Physician Marketing Activity � �� Yes Caution Not allowed 9. Publish an announcement for new physicians on the Hospital medical staff (only once and for all new physicians joining the medical staff). 10. Provide free or below cost hospital advertising services for a newly recruited physician while the physician is under a Recruitment Agreement with the hospital. 11. Publish a hospital ad that includes photos of physicians on staff in that service line (picture of OB physician with nursing staff on OB unit). 12. Product manufacturers or third parties offer free or discounted advertising (based on purchasing practices or not) which may mention Hospital by name. 13. Provide an advertisement for a joint venture with a physician. EMPLOYED PHYSICIANS PHYSICIANS UNDER CONTRACT WITH THE HOSPITAL TO PROVIDE A SERVICE BUT THE HOSPITAL BILLS AND COLLECTS FOR THE PROFESSIONAL SERVICES � � � 12 ALL OTHER PHYSICIANS (PHYSICIANS UNDER CONTRACT WITH THE HOSPITAL TO PROVIDE A SERVICE BUT THE PHYSICIAN BILLS AND COLLECTS FOR PROFESSIONAL SERVICES) i N/A N/A � The only way this service could be provided is to charge back the fair market value of the service to the physician or group. � ��Hospital owned service line and should rotate physicians selected. � �� Gray area. Best practice is to rotate physician selected in the picture and rotate among all significant hospital service lines, not just high referring service lines. N/A N/A � The activity is not permitted unless the costs are fully charged back and allocated in accordance with the percentage of ownership of the joint venture. 1 The term “all other physicians” includes non-employed, independent medical staff members and hospital/physician joint ventures such as imaging and ambulatory surgery centers. 2 Under the incidental medical staff benefits exception under Stark Law, the Hospital may provide members of the medical staff with items or services (non-cash) on campus so long as it is not based on the volume or value of referrals; is reasonably related to the provision of medical services and the Hospital’s mission, is less than $25 per occurrence (or is calculated into the $300 annual limit of non-monetary compensation) and the item or service is consistent with the types of benefits offered by other hospitals within the same local region. 3 When the hospital owns the service line and bills and collects for the physician’s professional fees, the hospital may use the fair market value or personal services exception under Stark. One key requirement of the fair market value and personal services exception is that the agreement between the parties be in writing for the services or items provided, among other requirements. 4 Under the non-monetary compensation exception under Stark Law, up to $300.00 per year, (non-cash) per physician, may be provided if all of the following conditions are satisfied: (i) the amount of the advertising support provided is not based in any manner that takes into account the value of volume of referrals or other business generated between the parties, (ii) the money is not solicited by the physician or the physician’s practice (including employees and staff members), (iii) the compensation arrangement does not violate the anti-kickback statue or any federal or state law governing billing or claims submission. The Hospital must have a system to track the item or service provided annually per physician. 5 Fair market value under Stark and the anti-kickback law is essentially the same; the value of the advertising services being provided in an arms-length transaction when the buyer and seller are not otherwise in a position to generate business for the other party. In other words, the value or cost of the advertising services is consistent with the cost of services purchased from a commercial advertising agency or at least the cost to the hospital providing the services if there is no comparable service that can be purchased from an outside vendor. Under the fair market value exception to �
Stark (assuming another exception does not apply), all advertising services or items being provided must be in writing; the value of the services being provided and payment expected; the agreement must specify the time period covered; and the value of the services must not take into consideration the value or volume of referrals between the parties. 107. Advertising and Marketing Policies All marketing projects follow an approval process. It starts with a request made by an administrative or service line representative that is sent to the marketing representative for that campus, who works with the system office creative team. A draft is then approved by the client (service, e.g.), then the president and/or marketing representative of the facility approves it and sends to the system office creative team. Jeff Murphy has final approval. All marketing activity, including media buying and creative, must be coordinated through the Saint Joseph Health System marketing department. All promotional items (T-shirts, pens, etc.) are purchased or approved through Angela Florek, aflorek@sje.sjhlex.org, or the marketing representative at the appropriate facility. [include the template form used in marketing] 108. Internal Communication Common Thread magazine: www.SaintJosephCommonThread.org inCommon electronic newsletter: www.SaintJosephHealthSystem.org/InCommon The Daily Line-Up stand-up meeting eMed physician electronic newsletter: www.SaintJosephPhysicians.org Common Thread is an 8.5” x 11” glossy magazine published 6 times a year. It is distributed to all Saint Joseph Health System employees, key CHI employees and displayed in waiting rooms and public areas throughout the system. It is available online for public viewing at www.SaintJosephCommonThread.org. The magazine’s content focuses on employees and their outreach inside and outside Saint Joseph Health System. Kara Fitzgerald is the editor: fitzgekl@sjhlex.org, 859.313.1845. Story ideas and suggestions may be sent to her directly or submitted online at www.SaintJosephCommonThread.org. inCommon is a weekly electronic newsletter containing details and short reports about organizational news, along with photos of recent events. It is sent to all Saint Joseph Health System employees’ work e-mail addresses. Issues of the newsletter are archived at www.SaintJosephHealthSystem.org/InCommon. Content is coordinated through Kara Fitzgerald: fitzgekl@sjhlex.org, 859.313.1845. The Daily Line-Up is delivered face-to-face Monday through Friday by department leaders to employees across Saint Joseph Health System. It is a standup five-minute presentation for new policies and procedures, daily information and breaking news within the organization. It consists of system news and facility news: system news is shared with all employees and facility news is customized according to the individual facility (exception: Saint Joseph Hospital, Saint Joseph East and Saint Joseph - Jessamine share the same facility news). Content is coordinated through Kara Fitzgerald: fitzgekl@sjhlex.org, 859.313.1845. 13 Deleted:
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Saint Joseph Health System Corporate Identity and Graphic ...

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