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Policy on Marketing to Consumers and Patient Referral Sources <br /> I. INTRODUCTION <br /> A. The objective of this Policy is to assist employees of NSMT in complying fully with all of the complex <br /> laws and regulations governing sales and marketing practices in the health care industry, <br /> B. This Policy governs interactions with all consumers, existing NSMT sources of patient referrals as well as <br /> those sources of referrals with whom NSMT is not currently doing business, but who may become NSMT <br /> sources of referrals. As this Policy cannot address all situations that may arise, this Policy also is intended to <br /> educate employees so they can recognize practices that are permissible, practices that are prohibited and <br /> practices for which employees should seek additional guidance from their supervisor and/or NSMT 's <br /> Management before proceeding. <br /> II. BRIEF OVERVIEW OF THE HEALTH CARE LAWS THAT REGULATE NSMT's MARKETING <br /> ACTIVITIES WITH SOURCES OF PATIENT REFERRALS <br /> It is against the law for anyone to offer anything of value to a consumer, referral source, or potential referral <br /> source, in order to influence that consumer, referral source or potential referral source to select NSMT's <br /> products or services for their patients. For more information, see NSMT's Policy on Health Care Laws. <br /> -T. GENERAL MARKETING POLICY FOR CONSUMERS AND POTENTIAL PATIENT REFERRAL <br /> SOURCES <br /> A. From time to time, NSMT may market its services directly to consumers and potential sources of patient <br /> referrals, and may desire to offer certain free items and services to consumers, potential referral sources or the <br /> general community in order to enhance NSMT's name recognition, visibility and goodwill in the community. <br /> B. Under no circumstances will employees of NSMT, or anyone acting on behalf of NSMT, offer any free item <br /> or service (or any item or service for less than a fair market value payment)outside the items authorized in this <br /> Policy to consumers, referral sources with whom NSMT is currently doing business or those referral sources <br /> with whom NSMT is not currently doing business, but who are in a position to do business with NSMT(i.e., <br /> become a referral source of NSMT). <br /> C. Marketing Personnel should not market NSMT's services as being "medically necessary" because the <br /> determination of medical necessity requires a case-by-case review of the particular facts and circumstances. <br /> Rather, it is important for Marketing Personnel to explain accurately what NSMT services may be covered <br /> depending upon key facts and circumstances. All Marketing Personnel shall receive training regarding <br /> "medical necessity" as part of their standard initial compliance training. This training shall be similar to the <br /> "medical necessity" training that Intake Personnel and Medical Transport Personnel will receive. See NSMT's <br /> Policies on Intake Personnel, Policy, Medical Transport Personnel and Policy on Medical Necessity. '. <br /> D. To prevent requests for services that are not medically necessary, Marketing Personnel, in conjunction with <br /> the Compliance Officer and Managment, shall develop a medical necessity training program for customers. <br /> This training should be available to all customers, and required for those requesting an excessive number of <br /> non-covered transports. In addition to the training, customers shall be provided with written material regarding <br /> 23 <br />