In addition to the information outlined in the Office of University Compliance’s November Compliance Chatter: The Gift Rules, specific considerations also apply to the giving and receiving of gifts in the healthcare environment. These considerations particularly apply when interacting with patients, visitors, or potential referral sources, such as physicians, vendors, or other people or entities with the ability to influence or recommend the use of goods, facilities, items, or services or who are in a position to refer patients to UConn Health.

With the holiday season upon us, keep the November gift highlights from the Office of University Compliance, the University Guide to the State Code of Ethics, and these key considerations in mind regarding the acceptance or offering of gifts with regard to patients, visitors, and Referral Sources:

1. Never solicit, or ask for, gifts. Solicitation of gifts may constitute an actual, potential, or perceived conflict of interest and/or violation of the Federal Anti-Kickback Statute.
2. Never accept or offer a gift intended to influence referrals or result in the purchase of goods or services from UConn Health, and avoid the acceptance or offering of gifts that may be perceived as having these effects.
3. Never accepts gifts of cash or cash equivalents (such as a gift card). Refer those wishing to make monetary gifts to the UConn Health Foundation, including to the Expressions of Gratitude.
4. For non-cash or non-cash equivalent gifts, never accept gifts of strictly personal benefit that exceed nominal value, such as tickets to a concert or sporting event (see the State Code of Ethics).
5. A department or clinical unit may accept a modest perishable gift, such as an edible item to be shared by all staff within that department or clinical unit, provided the value of the perishable gift does not exceed nominal value (see the State Code of Ethics).
6. Carefully consider the acceptance and offering of gifts, and contact UConn’s State Ethics Liaison, the Office of Healthcare Compliance & Privacy, and/or the UConn Health Office of the General Counsel if unclear about accepting a gift or if you’ve received a prohibited gift and do not know how to return it.

UConn State Ethics Liaison: Kim Fearney, kim.fearney@uconn.edu

Office of Healthcare Compliance & Privacy: ohcp@uchc.edu

UConn Health Office of the General Counsel: generalcounsel@uchc.edu