Question: Should our Medical Staff have a policy that governs the use of Medical Staff funds?
Answer: Many Medical Staffs have policies that outline guidelines for permissible expenditures of Medical Staff funds. All expenditures must comply with the Stark rules, the Medicare/Medicaid anti-kickback law, and (if applicable) IRS tax exemption rules. Some examples of expenditures that we have seen in such policies include sending flowers to a funeral or contributions towards a preferred charity in cases of death within a Staff member’s family, plant/fruit baskets to Staff members who are hospitalized and similar reasonable activities when consistent with the hospital’s tax-exempt status, Stark and anti-kickback laws. There are other appropriate uses of funds Medical Staff leaders can address in such policies. Having such a policy would help protect everyone in the event of a whistleblower claim or government investigation.
To learn more about how to appropriately manage Medical Staff funds, join HortySpringer attorneys Henry Casale and Alan Steinberg for an audio conference on September 3, 2013, entitled “Medical Staff Funds – Dues and Don’ts.”