Create A Gift Policy To Fight Marketing Kickbacks


Gift Policy

There are many marketing techniques used today to help generate revenue and build a successful home health agency. More often than not, there are many inappropriate ways to establish a relationship with other providers that are continuously implemented. It is important to stay within guidelines and follow the law when executing your agency’s marketing plan. One of the best ways to stay compliant and protect your agency is by having a policy in place. By doing so, it clarifies what your agency distinguishes as acceptable and unacceptable so there is no discrepancy that may compromise your agency.

In Decision Health’s book, Ultimate Guide to Home Health Marketing and Referrals, it is advised that companies use a gift policy to refrain from getting caught in-between the issues marketing kickbacks. Melanie Stover, President of a San Diego-based training and consulting company,, suggests using the 5 tips below to create formal guidelines when building your agency’s policy.

  1. Hold sales reps accountable. Make it a requirement that they track spending monthly to ensure they don’t exceed the safe harbor allowances.
  2. Put it in a manual. Make the introduction to the policy part of your training for new marketers.
  3. Identify a contact person. During times of confusion or doubt about whether a marketing strategy is acceptable this will be the person to contact.
  4. Include alternatives. Provide examples of sound strategies that you want practiced. Guide marketers to send thank you notes immediately after receiving referrals or updating physicians within one week of a patient’s admission to home care.
  5. Set clear limits. If you don’t want reps to spend more than $50 on lunch, make it clear in your policy that this is the maximum amount for the entire year, not the person or per-meal amount.

Helpful Link: For a template of an informational gift and marketing policy created by healthcare attorney Gabriel Imperato, go to:

Original Resource: Decision Health, Ultimate Guide to Home Health Marketing and Referrals

How has implementing a gift policy strengthened your business?