Grateful-Patient Program Compliance & Bedside-Boundaries Checklist
A field-ready go/no-go checklist a gift officer or clinical liaison runs before contacting a grateful patient — turning dense HIPAA/Stark/AKS rules into fast, defensible yes/no gates.
Draft: pending review
This starter document is signed off by Privacy officer + compliance officer (Stark/AKS) + foundation counsel + CFRE before it ships. The guardrails below define that review.
What’s inside
- Pre-contact gate: discharged and outside acute treatment? in the permissible data set? not on a suppression/opt-out list?
- Data-firewall check: surfaced through the approved pathway with no impermissible PHI attached?
- Bedside-boundaries checklist for clinician interactions
- Periodic-audit section: sample-pull, log-review, BAA-currency, training attestation
Legal & ethical guardrails
The sector-specific compliance points this document must honor.
- Enforces the HIPAA firewall and limited-data-set boundary at the point of action, confirming opt-out status before solicitation
- At the bedside the operative rule is the Anti-Kickback Statute / beneficiary-inducement, not Stark; gates confirm no solicitation during active care, no clinician referral incentives, and that the NPP fundraising statement was in force for the patient
- Protects vulnerable and restricted populations with explicit exclusion gates
- Creates an auditable compliance trail (logs, attestations) for privacy officers and regulators
Held for professional review.
The native PDF and full working text ship only after sign-off by Privacy officer + compliance officer (Stark/AKS) + foundation counsel + 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.