Triumph HealthCare recognizes that there are
legitimate and lawful reasons to accept or provide reasonable business
courtesies. Specifically, there will be times when employees may wish to accept
from a current or potential business associate an invitation to attend a social
event in order to further develop business relationships or take advantage of
educational opportunities. However, in healthcare, business courtesies pose a
risk for conflict of interest or fraud and/or abuse related to anti-kickback
laws and regulations. In recognition of these issues, this policy provides
guidelines for accepting and providing business courtesies.
1.
These guidelines only pertain to
relationships with individuals and entities outside Triumph HealthCare it does
not pertain to actions between the organization and its employees nor actions
among Triumph HealthCare employees.
2.
These guidelines do not cover gifts.
3. Any business courtesies involving physicians or
other individuals or entities in a position to refer patients or services to
the organization must strictly follow corporate policies and be in conformance
with all federal and state laws, regulations, and rules regarding these
practices.
4.
Under no
circumstances will an employee solicit business courtesies.
1. Employees may accept invitations to social events in order to further
develop business relationships; however, these events must not include expenses
paid for any travel costs or overnight lodging. The cost associated with such
an event must be reasonable and appropriate. This will mean that the cost will
not exceed $100.00 per person.
2. Employees may accept invitations to attend training, educational, or
informational opportunities that may include travel and overnight accommodations.
However, prior to accepting any such invitation, employees must receive written
approval from a senior member of the Triumph HealthCare management team
(Director or above).
3. Business courtesies that would influence or appear to influence an
employee in the conduct of their duties or responsibilities must be declined.
1.
Employees may extend invitations to
current or potential business associates to attend a social or educational
event. The purpose of the event must not
be to improperly influence relationships, business outcomes or referral
sources.
2.
During these events, topics of a
business nature must be discussed and the host must be present.
3. Costs associated with such an event must be reasonable and appropriate
and not exceed $100.00 per person. These events must not include expenses paid
for any travel costs or overnight lodging.
4. Such invitations must be infrequent with respect to any particular
individual or entity, which, as a general rule, means not more than once every
quarter.
Any departures from this policy must be approved in writing by a senior
member of the Triumph HealthCare management team (Director or above).