Grateful Patient Program Charter & Operating Framework
The foundational governance document that establishes a grateful-patient program and sets its boundaries — the document a foundation president brings to the board, compliance, and clinical leadership before any patient is contacted.
Draft: pending review
This starter document is signed off by Hospital foundation counsel (HIPAA) + privacy officer + compliance officer + CFRE before it ships. The guardrails below define that review.
What’s inside
- Program mission tied to a retention-first thesis over mass acquisition
- Governance RACI: board, CDO, compliance officer, privacy officer, clinical liaison, physician champions
- The HIPAA firewall in operational terms: who may access what, one-directional clinical-to-development flow
- Patient eligibility and suppression (behavioral health, minors, substance-use, reproductive care) and care-team veto
Legal & ethical guardrails
The sector-specific compliance points this document must honor.
- HIPAA (45 CFR §164.514(f)) permits fundraising use without authorization only of an ENUMERATED set — demographics, dates & department of service, treating physician, outcome, and health-insurance status — which is NOT the separate §164.514(e) 'limited data set'; anything richer (diagnosis, clinical detail) requires §164.508 authorization
- Every fundraising communication must carry a clear, conspicuous opt-out; treatment cannot be conditioned on fundraising choices
- Anti-Kickback/Stark: no physician receives value tied to referrals, and care is never influenced by philanthropic capacity
- Ethical duty to exclude actively-treated, frightened, or vulnerable patients; the care team retains override
Held for professional review.
The native DOCX and full working text ship only after sign-off by Hospital foundation counsel (HIPAA) + privacy officer + compliance officer + CFRE on this exact version. The summary and review requirements remain visible in the meantime.
Not legal advice. Not legal, tax, or accounting advice. The Fundraising Co. provides educational fundraising materials and is not a law firm; nothing here creates an attorney–client relationship or substitutes for advice from professionals licensed in your jurisdiction. Laws and IRS rules vary by state and change over time. Review every document with qualified counsel before use.