Hold on to your mouse, and set your coffee mugs down for this one.

Our hospital compliance officer has advised us that the recent (May 2009) revisions of the STARK regulations has implications for our aesthetics business and that every health care provider needs to prepare for further tightening.

She says we can't offer any referral incentives to clients in the form of an add on service. Okay.

She says we can't offer Botox Rewards. (Huh?)

She says we can't discount packages because it encourages self referrals and over-utilization. (WHAT?!)

While the current opinion is that the "STAND IN THE SHOES" doctrine connects the fee-for-service with the third-party world, she believes that sooner or later all physicians/medical services providers will be scrutinized for encouraging patients to over utilized medical care, reimbursable or not.

So effectively, her philosophy would do away with complimentary consultations, packages that include free product, packages that discount based on volume (i.e. 6 peels for the price of 5 or 1/2 second area of laser hair removal), 1/2 off your second syringe of filler, open-house or event specials, door prizes, or patient appreciation gifts.

Does anyone have any comments or opinions... hard facts or otherwise on this issue? Healthcare attorneys... if you're reading... love to hear from you on this.

are you employed by a hospital system?

Yes.

Yes.

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience

Beth, I don't see how this would even remotely apply to your situation ....are you TRYING to make your job harder and more confusing......it would appear that way. Your "hospital compliance officer" needs to crawl back under the rock she came from. Go bug the med-surg floors, ortho, who ever else she could spend her obviously vast amounts of free time on. This is disturbing.

SkinScience