Gift and Courtesy Standard
Purpose
This standard is the single reference for ABAS employees on giving and accepting gifts and courtesies. It states in plain terms what is allowed, and it is the source the compliance policies point to: POL-005 (Anti-Kickback Statutes), POL-008 (Improper Inducements), and POL-009 (Conflicts of Interest). Where those policies refer to items of nominal value or to ABAS's gift standard, they mean this document. When anything here is unclear, ask the Compliance Officer before giving or accepting.
The Standard
Cash is never allowed
Cash and cash equivalents, including gift cards, may never be given or accepted in any amount or in either direction.
Giving a gift or courtesy to a client or family
Permitted only if it is of nominal value, is not cash, is not advertised, and is not tied to a family's decision to choose or stay with ABAS. Nominal value here tracks current OIG nominal-value guidance; the current limit is in the Current Limits table below. Examples: a small thank-you card, or refreshments at a family training session.
Accepting an unsolicited gift from a client or family
Permitted only if it is of nominal value and is not cash. You may not solicit gifts. A gift over the limit must be declined or returned, and the offer reported to the Compliance Officer.
Anything involving a referral source or vendor
Always ask the Compliance Officer before giving or accepting anything of value. ABAS sets no fixed dollar limit here, because these arrangements carry anti-kickback risk (POL-005).
Current Limits
Reviewed at least annually by the Compliance Officer.
| Situation | Limit | Basis |
|---|---|---|
| Giving to a client or family | $15 per item, $75 per client per year | Current OIG nominal-value guidance |
| Accepting from a client or family | Under $50 from any single source per year | ABAS conflict-of-interest standard |
| Referral sources and vendors | No fixed limit; ask the Compliance Officer first | Anti-kickback risk (POL-005) |
| Cash or cash equivalents | Never, in any amount or direction | All of the above |
The giving limit is lower than the accepting limit because federal law restricts what a provider may give to clients in public programs, while the accepting limit reflects ABAS's own conflict-of-interest standard.
Maintenance and Review
The Compliance Officer owns this standard and reviews it at least annually. The client and family giving limit tracks current OIG nominal-value guidance; the Compliance Officer updates the figures here when OIG revises them and reviews all figures annually for inflation. Because POL-005, POL-008, and POL-009 point to this standard rather than to fixed numbers, updating a figure here does not require revising those policies. The Compliance Officer keeps a record of nominal items given to or accepted from each client and family so the annual aggregates can be confirmed against the limits.