Given the growing number of convenient care options in the marketplace, it might seem like a good idea to send mailers with urgent care coupons for discounts or other giveaways. But what are the risks associated with this marketing technique in the healthcare space?
There’s a criminal Anti-Kickback Statute that generally prohibits providers from giving anything of value to induce patients, services, or an item billable to a federal healthcare program. Both the giver and the receiver of the gift may violate the statute, according to Physicians Practice.
We’ve seen some urgent care flat mailers in recent years offering coffee shop gift cards, free first aid kits, and even $50 off medical services. Another flier from an urgent care center encourages patients to give a good rating on Yelp to receive a $25 gift card. Not only could this technique raise red flags over legal concerns, the Yelp website has policies against incentivizing consumers for reviews.
There is some gray area surrounding the law. The Office of the Inspector General has determined that incentives of nominal value (not more than $10 per item, or $50 total for one year, to a single individual) are acceptable. Many states also have laws that prohibit patient referral or incentivizing practices. There’s also the Anti-Inducement Provision of the Social Security Act, which says a person can face civil monetary penalties for offering remuneration to any beneficiary eligible under Medicare or a state healthcare program.
These marketing techniques could certainly appeal to cost-conscious residents in the area, but it’s not the best idea.
Looking at the examples from above, a coffee gift card or free first aid kit is unlikely to trigger legal action. But it’s important that providers are considering these regulations when devising an urgent care coupon strategy. Disregarding the federal statutes, or similar provisions set up at the state level, puts your professional license in jeopardy.
In addition, insurance payors don’t allow discounting of co-pays and other patient responsibilities as outlined in the contracts.
[box] Couponing is marketing technique to elicit a direct response, but urgent care is generally not a discretionary purchase. People in need of urgent care will seek it when needed regardless of the incentive. Consumer behavior may drive them to save your coupon for a future urgent care need. This could help them choose your urgent care center over a competitor, but it also raises potential issues: If the coupon expires, will the center still accept it? If offering a giveaway, what happens when you run out and a consumer comes in later to claim one? And, if the consumer forgets the coupon would you still honor the discount? If not, what are you risking by sending away an unhappy customer?[/box]
Instead of coupons and/or giveaways, consider the following four marketing tactics:
The impact of these marketing techniques may not be immediate when compared to a patient walking through the door to redeem the coupon mailer just sent out. But the payoff from building a solid brand foundation and comprehensive strategy is less risky and longer lasting.