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tci Outpatient Facility Coding Alert - 2018 Issue 3

Reader Question: Delve Into Nuances of CMPL

Question: What are some things we need to remember when offering complimentary items or services in our ASC? Florida Subscriber Answer: The Civil Monetary Penalties Law (CMPL) prohibits many different behaviors, but in terms of marketing, it prohibits offering, soliciting, or receiving kickbacks for referrals. It also prohibits offering inducements to program beneficiaries if you know or should know that the remuneration is likely to influence that beneficiary's decision to recommend your surgery center to others or utilize it themselves. The government is looking at whether or not the remuneration will affect the patient's choice of facility or provider...

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