SolutionHealth Gifting Guide!

It’s the holiday season which means a time of giving, but employees at SolutionHealth need to be aware of policies surrounding gifts.

Accepting gifts and other donations from vendors and patients may implicate the federal anti-kickback statute (“AKS”), Stark Law, and other applicable health care laws. The intent of these laws is to ensure that the patient-caregiver relationship is not influenced by gifts.

To help, the SolutionHealth Compliance Team has put together this guide for gifts:

What types of gifts or reimbursements are allowed?

Certain gifts of nominal value (please see applicable member organization’s specific policy for definition of nominal value) are allowed. These include:

• Promotional items (pens, notepads, mugs, or similar items) from vendors
• Meals, snacks, or beverages from vendors
• Gifts and non-monetary items from patients (example: baked goods)

Gifts between employees or among people who have independent personal relationships are allowed if the gift is not intended to influence nor perceived to be influencing the status or compensation of the gift giver or receiver.

Please see the following SolutionHealth member organization’s “Gift Policies” for more examples of acceptable and unacceptable gifts:

• Elliot Health System: Proper Vendor Interactions and Offering and Receiving of Gifts and NonMonetary Compensation
• Southern New Hampshire Health: Receipt or Solicitation of Gifts, Discounts, Gratuities, or Other Benefits

Do I need to follow this policy if I am a non-employed provider?

Yes! The gift policies apply to all workforce members of SolutionHealth and its member organizations, including employed and non-employed providers. We highly recommend that non-employed providers maintain documentation as outlined in the applicable policy of any gifts received.

What types of gifts are not allowed?

• Any offered gift which could be perceived as influencing referrals.
• Gift certificates, gift cards, stocks, bonds, or other cash and cash equivalents from vendors, unless permitted by the gift policy.
• Any gift above the nominal value as defined by each member organization’s policy

What about gifts during the holiday season?

SolutionHealth discourages current and prospective vendors from offering holiday gifts.

Employees should refer anyone interested in making a gift to a SolutionHealth member entity to the following contacts:

• Elliot Health System: Mary & John Elliot Charitable Foundation (Telephone: 603- 663-8934; Email: foundation@elliothospital.org)
• Southern New Hampshire Health: Legacy Trust (Email: LegacyTrust@snhhs.org; Website: legacytrustnh.org)

If individuals receive unsolicited, modest perishable or consumable gifts such as cookies, candy, or gift baskets from vendors or patients, such gifts may be accepted if they are shared among colleagues.

May I solicit gifts for SolutionHealth or a member organization?

All workforce members are prohibited from soliciting gifts. Vendors may only be solicited by the applicable charitable foundation for the funding priorities dictated by the appropriate board of directors.

What if I am not sure whether the gift is appropriate?

Any questions related to gifts should be directed to the SolutionHealth Compliance Department by email at Compliance@SolutionHealth.org.

Happy Holidays!

The SolutionHealth Compliance Department!