Many hospitals, clinics and other healthcare providers sponsor community health screening events to raise awareness of personal health issues and to provide information on available healthcare services. The Medicare or Medicaid programs, however, limit providers the free items and services that can be provided to beneficiaries.
OIG Advisory Opinion 09-11 analyzed a free screening program under which a small, county-owned critical access hospital would provide free blood pressure checks for any visitor to the hospital who requested one. Screened visitors would not be directed by hospital staff or administrators to utilize the services of any particular healthcare practitioner or provider. No special discounts were offered on follow-up services. If a screened visitor has an abnormal blood pressure reading, the visitor will be advised to see his or her own healthcare professional or, if clinical circumstances demand, the visitor may be directed to an emergency room for an emergency examination.
In the Advisory Opinion, the OIG concluded that free screenings were permissible. The OIG also noted that the free blood pressure checks would fall within a regulatory exception implementing the Civil Monetary Penalties (CMP) statute that allows incentives to be offered to individuals to promote the delivery of preventative care.
Practitioners or providers that participate in Medicare or Medicaid or other federal healthcare programs must structure carefully free community health screenings to (1) satisfy an exception to the CMP, such as incentives offered to promote preventative care; (2) avoid tying the free service to other services offered by the practitioner or provider; and (3) refrain from directing the individual to any particular practitioner or provider, including incentives or discounts on follow-up services, or offering to make appointments with the provider's own affiliated practitioners. Participants needing follow-up care should be directed to see their own practitioner or provider.