Streamlining Compliance: Enhancing Contract Lifecycle Management with Integrated Gift Tracking

U.S. healthcare entities are required to track all non-monetary compensation (i.e., gifts) to affiliated providers and ensure that the total value of these gifts does not exceed the annual limit provided by the Department of Health and Human Services. However, hospitals and health systems often lack controlled, enterprise-level mechanisms for capturing this data — instead, they are tracking it throughout the year in disparate spreadsheets with limited oversight, few controls and a heavy reliance on individual reporting.

Most healthcare organizations track provider engagement from recruitment or initial affiliation, documenting obligations, compliance, and reporting responsibilities through the contracting process, which informs long-term compliance monitoring. But given that gifts are often exchanged at an individual level, manually managing this information against individual provider arrangements, thresholds, and regulatory requirements adds operational complexity and increases the risk of unintentional violations.

In 2022, the U.S. Department of Justice (DOJ) reported that recoveries from settlements and judgments under the False Claims Act exceeded $2 billion, and over 80% of all recoveries came from the healthcare industry. While this report alleges unlawful acts and illegal kickbacks, the reality is that even good faith exchanges can prove perilous when teams fail to effectively manage their contract lifecycle at an enterprise level.

Fortunately, there is an opportunity to expand existing contract lifecycles to include gift tracking and avoid the reputational and financial impact of AKS offenses. By integrating gift tracking as part of the overall contract management function, healthcare systems have an opportunity to validate gift details on a regular basis, track data at the recipient or facility level and configure processes to include validations and protections for both the recipient and the entity.

Here are several ways healthcare teams can advance their overall compliance and reclaim value for their organization through an integrated gift tracking solution:

1. Establish clear rules and procedures around gift acceptance. By having well-defined gift policies and procedures in one place, organizations can ensure that gift acceptance only occurs when the exchange meets certain criteria or advances legitimate business needs.

2. Utilize automated workflows for gift requests. Automated workflows within a contract lifecycle management system help ensure that all gift requests receive appropriate review and approval. Additionally, as federal regulations and internal policies change, updates to gift tracking workflows can be deployed immediately, ensuring both the system and the recipient are current and compliant.

3. Facilitate gift tracking across all departments. With gift tracking capabilities, gift managers can quickly access gift information at any time to ensure that transactions are accurately tracked and fully compliant. There’s no need to manually exchange information across teams, and key stakeholders will always have the necessary data right at their fingertips.

4. Constantly monitor gift activities against compliance requirements. By closely monitoring gift activities in a single system, organizations can promptly identify any potential irregularities or conflicts of interest and address them within the required resolution windows. Increased data accuracy also helps to ensure that gifts are tracked accurately from start to finish.

Healthcare teams work hard to improve the patient experience and deliver safer care, and gifts are given for positive reasons. As such, the process of managing them should be an opportunity to celebrate, not a compliance headache.

Integrating a comprehensive gift tracking solution into your contract management lifecycle is essential for effectively administering this compliance process, while also promoting a culture of transparency and trust. With greater centralization and proactive analysis, healthcare organizations can save time and money, build greater credibility and reinvest in better outcomes and experiences for patients and staff alike.

Interested in learning how you can advance your contract lifecycle management process? Speak to one of our experts today.

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