HSE LEGALcurrents®

On a daily basis, hospitals and health systems move further away from a health care delivery system in which fee-for-service reimbursement is the dominant reimbursement scheme.  Pay-for-performance models are in wide use today.  Under these models, health systems now strive to prevent hospitalizations, to treat patients in the lowest acuity setting that is appropriate and to find ways to ensure that patients keep their appointments so that their conditions can be appropriately managed.  One way in which health systems seek to meet these goals is through the development of free or subsidized patient transportation programs.  Companies like Uber and Lyft have started to cater to health care clients seeking to provide free rides to their appointments and between health care settings.  Some health systems have developed their own programs.  Unfortunately, health care remains one of the few industries where the gift of free services to customers can create legal trouble.  While the federal anti-kickback and beneficiary inducement rules applicable to patient transportation programs have been relaxed in recent years, health systems must give careful thought to the design of these programs to avoid compliance issues.   

If you have any questions, please contact a member of our Health Care team at (585) 232.6500.

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