Aug 11 2009

OIG Advisory Opinion Approves Free Blood Pressure Screenings

In an Advisory Opinion posted on August 10, the OIG said a hospital could provide free blood pressure screenings to walk-in visitors at the hospital without the threat of sanctions under certain circumstances.

The Opinion centered around an arrangement whereby a small critical access hospital provides free blood pressure checks to any visitor who enters requesting the service during daylight hours. The hospital does not advertise the free screening, and it is not conditioned on the visitor’s use of any other goods or services from the hospital or any other particular health care provider. Hospital staff responds to abnormal blood pressure readings obtained during a free check by advising the visitor to see his or her own health care professional.

In issuing its Opinion, the OIG found the arrangement met the preventive care exception of the Anti-Kickback Statute, which allows for the provision of a free non-covered screening as long as the screening is not tied to the provision of other hospital-provided services reimbursed in whole or in part by Medicare or an applicable state health care program.

The Opinion also reiterated previous guidance, which stated that similar arrangements that also involve the scheduling of appointments with hospital providers, discounting of additional covered services, or promotion of its programs may violate the prohibition on beneficiary inducements.

Providers contemplating similar screening services should carefully review and structure such arrangements to avoid improper ties to the provision of other services.