By name: hospice-sales-compliance description: "Veteran playbook for hospice referral-marketing compliance — the Anti-Kickback Statute and its hospice-relevant safe harbors, Stark, the beneficiary-inducement CMP, the gift/meal nominal-value discipline, OIG hospice risk areas, truthful-marketing rules, and HIPAA for a liaison. Consulted by hospice-sales-compliance-advisor. Frames the question and names the rule and safe harbor; routes the RULING to the compliance officer / counsel."
Hospice Sales Compliance Skill
Purpose: help hospice-sales-compliance-advisor frame the compliance question correctly — name the rule, flag the risk, give the safe-harbor structure — and route the ruling to the agency compliance officer and counsel.
The line (applies to everything below)
Frame the question; never issue the ruling. The correct output is "here is the rule, here is the line, here is the safe-harbor structure, here is the question to put to your compliance officer" — not "yes, that's fine." Hospice is high-enforcement (OIG work plans, False Claims Act settlements); when in doubt, stop and ask the compliance officer. Every threshold here is [example — confirm against the current rule / your compliance officer]. (../CLAUDE.md §3 #2, §5, §10.)
When to use
- Any gift, meal, sponsorship, free service, staffing, or space arrangement involving a referral source.
- Any inducement that reaches a patient/family.
- Any marketing piece or outreach message.
- Any handling of PHI.
1. Anti-Kickback Statute (AKS)
The federal criminal prohibition on knowingly offering/paying/soliciting/receiving remuneration to induce referrals of items or services payable by a federal healthcare program. Intent-based and broad — "remuneration" includes anything of value. Hospice referral-source relationships are squarely in scope. Safe harbors protect specific structures only if every element is met — see resources/aks-safe-harbors.md. The relevant ones for a liaison's world:
- Personal services & management contracts — a written agreement, ≥1-year term, aggregate compensation set in advance at fair market value, not determined by the volume or value of referrals.
- Space / equipment rental — written, ≥1-year, fair market value, not volume-based.
- Employees — bona fide employees are protected (this is why a hospice's own W-2 liaisons are not the AKS problem; arrangements with outside sources are).
2. Stark (physician self-referral)
A strict-liability civil law: a physician may not refer designated health services to an entity with which the physician (or an immediate family member) has a financial relationship, unless an exception is met. Where a referral source is a physician, Stark applies in addition to AKS — and Stark has no intent requirement, so a technical violation is still a violation. Route physician arrangements to counsel.
3. Beneficiary-inducement CMP
Prohibits offering remuneration to a Medicare/Medicaid beneficiary that is likely to influence their choice of provider. Gifts to patients/families must fit the nominal-value exception (small per-item and annual caps — [example — confirm the current CMS figures]) and never be cash or cash-equivalents.
4. Gifts, meals, sponsorships (the nominal-value discipline)
"Small and infrequent" is a documented structure, not a feeling:
- Non-cash, never cash or cash-equivalents (no gift cards).
- Within the published per-item and annual nominal-value limits — cite them; treat any remembered figure as
[example — confirm]. - Not tied to referral volume or value in any way.
- Documented. An undocumented pattern of meals is a pattern, and a pattern is what OIG looks at.
5. Truthful marketing
No eligibility or coverage guarantee, no misleading or unsubstantiated claim, no competitor disparagement with unverified facts, no pressure on a vulnerable family. Read every piece for those four failures.
6. OIG hospice risk areas
The published enforcement themes that make referral-source arrangements high-scrutiny: ineligible patients / inappropriately long lengths of stay, improper financial relationships with nursing facilities and physicians, and GIP (general inpatient) misuse. These are why the default posture is caution.
7. HIPAA / PHI for a liaison
A liaison handles real patient data. Minimum-necessary, a HIPAA-safe boundary, and nothing patient-identifying in a CRM note shared out, an email, an example, or a scenario. Route any PHI question beyond minimum-necessary framing to the privacy officer.
The output pattern
For any ask: name the rule → locate the line → give the safe-harbor structure (if any) → state the specific question to put to the compliance officer → never green-light. Run the ## Decision Tree: Gift / meal / arrangement anti-kickback gate in the knowledge bank; it ends at "route to compliance officer."
Hand-offs
- The actual ruling → the agency compliance officer / healthcare counsel (always).
- A revised rule / OIG advisory opinion / safe-harbor change →
ravenclaude-coredeep-researcher. - PHI handling beyond framing →
ravenclaude-coresecurity-reviewer+ the privacy officer. - The eligibility accuracy a marketing piece relies on →
hospice-eligibility-criteriaskill /hospice-eligibility-educator.