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Partnering with churches and community groups: a marketing and compliance guide for practices

How a practice can partner with a church or community group on health events: sign-up sheets, photos, gifts, co-branded flyers and the host’s tax rules.

A pastor asks whether your practice would run a blood pressure table after services next month. A neighborhood association wants a talk on knee pain at its spring meeting. A food pantry would like a dentist to look at children’s teeth on a Saturday. These invitations are a real way to meet people where they already gather, and they come with a partner whose rules, reputation and members are not yours to spend.

This guide is about the partnership itself: who does what, who holds the names, what the flyer may say, what the practice may give and pay, and what the host has to watch as a tax exempt organization. For running the screening table, see our guide to health fairs and free screening events. For paying to put your name on a program, see healthcare sponsorships and naming rights. For promising a donation to the host for each new patient, see our charity donation promotion guide. Partnerships built around food or housing help connect to social needs screening outreach.

This is general information, not legal advice. Sources cited were checked on October 30, 2026: 42 U.S.C. 1320a-7a and 1320a-7b, 42 CFR 1001.952(b), the HHS OIG Policy Statement Regarding Gifts of Nominal Value (December 7, 2016), 45 CFR 160.103, 164.501, 164.502 and 164.508, the HHS OCR sign-in sheet FAQ, 26 U.S.C. 501(c)(3) and 513(i), 26 CFR 1.513-4, the IRS page on political campaign intervention by 501(c)(3) organizations, and 16 CFR 255.4 and 255.5. State rules on health screenings, privacy and professional advertising differ from state to state, so check yours, and have a health care attorney review any written partnership before you sign it.

The short version

  • Put the partnership in writing. One page that says who runs the event, who collects what information, who pays for what, and what each side may say about the other heads off the trouble below.
  • Decide who holds the sign-up list before the first flyer goes out. Names a church collects for its own ministry are the church’s. Health details your practice collects while screening someone are your practice’s to protect under HIPAA.
  • Gifts to attendees have a limit when Medicare or Medicaid patients are in the room. The OIG reads nominal value as no more than 15 dollars per item and 75 dollars per patient per year, and never cash or cash equivalents.
  • Do not pay the host for patients. Payments to a partner that track the number of people who become patients raise federal anti-kickback concerns. Rent for space should be at fair market value and set in advance.
  • The host’s tax exemption sets limits on the event. A 501(c)(3) organization may not take part in a campaign for or against a candidate, so keep the event free of candidate content.
  • A co-branded flyer is your ad, too. Health claims on it must be true and backed up, and the host’s name on it should not suggest an endorsement the host never gave.

Why partnerships need their own plan

At a health fair you rent a table and run it. In a partnership, a second organization lends you its name, its building, its members’ trust and its channels: the bulletin, the email list, the announcements from the front. That is what makes the outreach work, and it is also why each side needs to know what the other will do.

The host may be a church, a mosque, a synagogue, a temple, a civic club, a senior center, a tenant association or a food bank. Their leaders know their members, and they will be asked about anything that goes wrong. A short written agreement protects them as much as it protects the practice, and it makes it easier for them to say yes the next time.

Who holds the sign-up sheet

The first question to settle is who collects names, and what else is on the sheet. A sign-up sheet for a talk that asks for a name and an email, kept by the host for its own events, is the host’s list. The host is not a health care provider, and its own list is not protected health information held by your practice.

Things change once your practice is involved in care. If your staff take blood pressures, record readings or note symptoms, the information they collect about each person is health information your practice creates as a provider. If your practice is a HIPAA covered entity, that information is subject to the Privacy Rule, and the sheet, the readings and any follow-up list need the same safeguards as your office records. The HHS Office for Civil Rights says providers may use sign-in sheets, as long as they limit the information on them and apply reasonable safeguards, which means no reason for the visit on a sheet anyone in line can read.

Watch for the middle case. If the host collects screening forms, results or intake details on your practice’s behalf, for example by handing out your health questionnaire and passing the completed forms to you, the host may be doing work for your practice that involves protected health information. Under 45 CFR 160.103, a person who creates, receives, maintains or transmits protected health information on behalf of a covered entity can be a business associate. The simpler plan is to keep health information in your practice’s hands only: your staff hand out, collect and carry your forms, and the host’s sheet holds names and contact details for its own event list.

Using the list after the event

A list of people who came to a church health talk is not a list of patients. If the host shares its attendee list with you, ask what the host told people when they signed up, and use it only within that. If the list came from your own screening table, it holds health information, and HIPAA governs what you may do with it.

Under 45 CFR 164.508(a)(3), a covered entity needs a signed authorization before it uses protected health information for marketing, with two narrow exceptions: a face-to-face communication, and a promotional gift of nominal value. A follow-up call about a high blood pressure reading the person asked you to make is care. An email campaign about your new weight loss program sent to each person who had a reading taken is marketing and needs authorization. Write down which follow-up each person agreed to, on the form itself.

Photos and stories from the event

Hosts want photos for their newsletters and social pages, and so do practices. Agree in advance on three things: who takes photos, where they will be used, and how people say no.

  • Post a sign at the entrance and at the screening area that says photos may be taken and how to opt out.
  • Do not photograph people while they are being screened, examined or told their results, unless they sign a written release first. A photo of your staff taking someone’s blood pressure shows that person receiving care.
  • If the photo is for your practice’s marketing and shows someone receiving care, treat it as patient information and get a HIPAA authorization, not only a general photo release.
  • Get a parent or guardian’s written permission before photographing children, and agree that the host will not post photos of children receiving care.
  • If a person later asks for a photo to come down, both sides take it down. Put that promise in the agreement.

Gifts, raffles and free services

Partner events run on small giveaways: water bottles, tote bags, a raffle for a gift basket. If Medicare or Medicaid patients attend, the federal beneficiary inducement law applies. Under 42 U.S.C. 1320a-7a(a)(5), a person who offers or transfers remuneration to a Medicare or Medicaid beneficiary that the person knows or should know is likely to influence the beneficiary to choose a particular provider can face civil monetary penalties.

In its December 7, 2016 policy statement, the HHS Office of Inspector General said it reads nominal value as a retail value of no more than 15 dollars per item, or 75 dollars in the aggregate per patient on an annual basis. Items may not be cash or cash equivalents, so a gift card is a problem even at a low amount. Items at or below the limits do not need to fit an exception. Count event gifts toward the yearly total for any attendee who is or becomes your patient.

Free screenings and free services are remuneration too. The statute has exceptions, such as items or services that promote access to care and pose a low risk of harm, but whether one fits depends on the facts. Our health fair guide covers free screenings at the table in more detail.

Money between the practice and the host

Partnerships involve money in both directions: a practice may pay rent for a fellowship hall, donate to the food pantry, or cover the cost of printing. The question for each payment is whether it could look like payment for patients. The federal anti-kickback statute, 42 U.S.C. 1320a-7b(b), makes it a crime to knowingly and willfully offer or pay remuneration to induce referrals of items or services paid for by federal health care programs.

  • Rent: the space rental safe harbor at 42 CFR 1001.952(b) protects lease payments that meet all six of its standards, including a signed written lease of at least one year that specifies the exact schedule of periodic use, rent set in advance at fair market value, and rent not tied to referrals. A one-off room fee may not fit all six standards, so keep the amount at the going rate for any renter and ask your attorney how to document it.
  • Donations: a gift to the host’s ministry or program should not depend on the number of members who book appointments, and should not be promised in exchange for promotion from the pulpit or the newsletter.
  • Per-patient amounts: avoid any payment calculated per sign-up, per new patient or per appointment. That is the shape the anti-kickback statute is concerned with.

The OIG issues advisory opinions on specific arrangements, but an opinion binds only the parties who asked for it. Our sponsorships guide explains how advisory opinions work.

The host’s nonprofit rules

Churches and other charities are generally exempt from federal income tax under 26 U.S.C. 501(c)(3). The statute’s text requires that such an organization not participate in, or intervene in, any political campaign on behalf of or in opposition to any candidate for public office, including by publishing or distributing statements. The IRS describes the prohibition as absolute and says violations can lead to the loss of tax exempt status and to excise taxes.

For the practice, the practical rule is simple: keep candidate content out of anything tied to the partnership. No candidate on the program, no campaign materials at your table, no flyers that mention an election. The IRS says nonpartisan voter education and voter registration are not prohibited when they show no bias, but a health event does not need either. If a candidate shows up, your staff should treat them like any other attendee.

When you pay to support the host

If your practice gives money to a nonprofit host and the host thanks you publicly, the wording of the thank you matters to the host’s taxes. Under 26 U.S.C. 513(i) and 26 CFR 1.513-4, a qualified sponsorship payment is one where the sponsor expects no substantial return benefit beyond the use or acknowledgment of its name or logo. The regulation allows the acknowledgment to include your logo, your locations, phone number and web address, and value-neutral descriptions of your services.

The same regulation says advertising includes messages with qualitative or comparative language, price information or other indications of savings or value, an endorsement, or an inducement to purchase or use a service, and that one message with both advertising and an acknowledgment is advertising. So “Thanks to [Practice name], family dentistry, [Town], [phone]” fits the acknowledgment pattern, while “Thanks to [Practice name], the best dentist in [Town], 20 percent off cleanings for members” reads as advertising. Let the host decide its own wording with its tax adviser, and do not press for more.

Co-branded flyers and announcements

When a flyer carries both logos, both organizations are speaking. For your practice, the health claims on it are your advertising, and the FTC Act’s ban on deceptive practices applies to it the same way it applies to your website. Describe what the event offers, who will be there, and what it is not.

  • Say what the screening is and is not: “Free blood pressure checks. This is a screening, not a diagnosis.”
  • Name the clinicians by their real credentials.
  • Do not promise results or a cure, or say that the event replaces a visit to a person’s own doctor.
  • Make it clear who is running the screening: “Screenings provided by [Practice name]. Hosted by [Host name].”
  • If the event is also a chance to book appointments, say so on the flyer.

The host’s name on the flyer is not an endorsement unless the host has actually endorsed your practice. Under 16 CFR 255.4, an organization’s endorsement must come from a process that fairly reflects the organization’s collective judgment. A line such as “recommended by [Host name]” should only appear if the host’s leadership decided to say it. If a pastor or leader speaks about your practice and has a connection the audience would not expect, such as being a patient who received free care or a relative who works at the practice, 16 CFR 255.5 says that connection should be disclosed clearly. The simplest version is a leader who introduces the event and does not recommend the practice.

What the written agreement should cover

A partnership agreement does not need to be long. Keep a copy signed by someone with authority on each side, and have your attorney look at it before the first event. It should state:

  • the date, place and hours of each event, and what each side will provide;
  • who collects which information, where it is kept, and that health information stays with the practice;
  • the photo plan, the opt-out signs and the takedown promise;
  • which gifts or giveaways the practice will offer, and their retail value;
  • any money that changes hands, its amount, how it was set, and that it does not depend on referrals;
  • who approves flyers, posts and announcements before they go out, and that no political content will appear;
  • how either side can end the partnership, and what happens to shared materials when it ends.

Questions to ask before you say yes

  • Who at the host has the authority to agree to this, and who will we work with on the day?
  • Will any health information be collected, and does our plan keep it in our staff’s hands?
  • What will the host tell its members about how their names will be used?
  • Will Medicare or Medicaid patients be present, and what is the retail value of each item we plan to hand out?
  • Is any money going to the host, and could anyone read it as payment for patients?
  • Who reviews the flyer, and does each health claim on it have support?
  • Is there an election coming, and have we kept candidate content out of all materials?

Use and avoid

  • Use: “Free blood pressure checks after the 11 o’clock service, provided by [Practice name]. A screening, not a diagnosis.” Avoid: “Free checkup with Dr. [Name], recommended by Pastor [Name].” unless the pastor agreed to that wording and any connection is disclosed.
  • Use: “Thank you to [Practice name], [Town], [phone], for supporting our health ministry.” Avoid: “Thank you to [Practice name], the best clinic in town. Members get 10 percent off.”
  • Use: a name-only sign-up sheet held by the host, plus your own screening forms kept by your staff. Avoid: one shared clipboard with names, readings and symptoms passed around the hall.
  • Use: a water bottle or a pill organizer as a giveaway. Avoid: gift cards for anyone who books an appointment.

An illustration

This example is invented. [Practice name], an independent family practice in [Town], agrees to run a heart health morning at [Host name], a church with a health ministry. The practice manager and the ministry leader sign a one-page agreement. The church will promote the event in its bulletin and reserve the fellowship hall at no charge. The practice will bring two clinicians to take blood pressures, give a short talk on reading a blood pressure number, and hand out pill organizers with a retail value of [amount], under the OIG limit.

The church keeps a sign-up sheet with names and emails for its own ministry list. The practice’s staff keep their own screening forms in a closed folder, write readings only on those forms, and ask each person whether they want a follow-up call. The flyer says who hosts and who provides the screenings, that it is not a diagnosis, and that people can book an appointment if they want one. A sign at the door explains the photo policy, and the church photographer takes photos only of the talk. The practice’s next newsletter mentions the event without naming or showing any attendee.

Checklist

  • A written agreement is signed by both sides.
  • Health information is collected only by practice staff and kept by the practice.
  • Sign-in sheets carry only what is needed and are not left open.
  • Follow-up permission is recorded on each person’s form.
  • Gifts are below 15 dollars per item and are not cash or gift cards.
  • Any money to the host is at fair market value, set in advance and not tied to referrals.
  • The flyer names the host and the provider, and each claim is supported.
  • No candidate or campaign content appears in any material.
  • Photo signs are up, care is not photographed without written permission, and takedown requests are honored.

How we help

We build practice websites, local SEO, Google Ads and lead generation and an AI front desk for independent practices. For community partnerships, we build event pages and sign-up forms that ask only for what the event needs, and we draft co-branded flyers and follow-up messages for your review and your attorney’s. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it. We are not a healthcare provider and we do not give legal or medical advice. For the wider rules, see our healthcare marketing rules guide.

Is a church sign-up sheet protected health information?

A sheet the church keeps for its own event, with names and contact details, is the church’s own list. Health information your practice collects while screening people, such as readings or symptoms, is information your practice creates as a provider, and if your practice is a HIPAA covered entity, it must be protected under the Privacy Rule. Keep health details on your own forms, held by your staff.

Can we give gifts to people at a community health event?

Yes, within limits when Medicare or Medicaid patients may attend. The HHS OIG reads nominal value as no more than 15 dollars per item or 75 dollars per patient per year, and gifts may not be cash or cash equivalents such as gift cards. Larger gifts would need to fit an exception to the beneficiary inducement law.

Can we pay the church for hosting the event?

You can pay for space or services at fair market value, with the amount set in advance and not tied to the number of people who become patients. The anti-kickback statute concerns payments meant to induce referrals for federal health care program business. Ask your attorney how to document a room fee, since the space rental safe harbor has six standards.

Can the pastor recommend our practice to the congregation?

A recommendation is an endorsement. If it comes from the church as an organization, it should reflect the organization’s actual decision, and if the speaker has a connection to the practice the audience would not expect, the FTC Endorsement Guides say it must be disclosed. A neutral introduction of the event avoids both issues.

Can we hand out information about a candidate or a ballot measure at a church event?

Keep candidate content out of the partnership. A 501(c)(3) organization may not take part in a campaign for or against a candidate for public office, and the IRS says violations can cost the organization its tax exemption. A health event does not need political content of any kind.

Sources

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