C-ATM Course 6: Ethical Compensation Practices

Because applied knowledge is power, and your reputation is everything.

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In this course you explore the fundamental questions, "What are ethical compensation practices?" and "Why are they so important for healthcare marketers?" With legal expert, Harry Nelson as your guide, you examine legal and ethical best practices for contracting and compensating marketers, call centers, and laboratories. You also consider how best to avoid compensation misconduct, including inducements and kickbacks, fraud and abuse, and patient brokering.

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In this course you will analyze key principles and best practices related to:

  • Federal and state law
  • Compensation of marketers, call centers, and laboratories
  • Contracts and tax status reporting
  • Avoiding compensation misconduct



Click on any of the modules below to see the content.

Module 1: Introduction to Ethical Compensation
  • Laws and regulations
  • Enforcement activity
  • Ethical rules
  • Inducements and kickbacks
  • Federal Anti-Kickback Statute
Module 2: Fraud and Abuse
  • Types of fraud
  • Types of abuse
  • Criminal liability
  • Civil liability
  • Disgorgement
  • Exclusion
  • Reputational damage
Module 3: Inducements and Kickbacks
  • Transportation
  • Family members
  • Childcare
  • Health insurance
  • Housing
  • Urine drug testing
Module 4: Marketer Compensation - Part 1
  • Lawful contracts
  • W2 employees
  • 1099 contractors
  • State wage and hour laws
Module 5: Marketer Compensation - Part 2
  • Fair market value
  • Commercial reasonableness
  • Bonuses
  • Bona fide employees
Module 6: Marketer Compensation - Part
  • Disguised compensation
  • Personal services and management contracts
  • Personal services safe harbor principles
Module 7: Call Centers and Laboratories
  • Outside call centers
  • Unqualified and qualified leads
  • Laboratory services
  • Case Study: Healthcare Marketing Florida
Module 8: Gifting
  • Non-cash gifts
  • Tax reporting of gifts
  • Gifts of nominal value
  • Cash cards and gift certificates
  • Meals and events
  • Gifts for family of patients
Module 9: Referral Relationships
  • Self-referral
  • Federal laws (Stark Law)
  • State laws
  • Capping, steering, and running
  • Case Study: Rent-a-Patient Scandal
Module 10: Patient Brokering
  • Florida anti-kickback laws
  • California anti-kickback laws
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Available 10/15/18

You will be able to take the course, with or without CE Credits


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Behavioral Health Association of Providers (BHAP)

A National Trade Membership Association that provides education and advocacy for behavioral healthcare providers and related entities.