Medical office grand opening: gifts and raffles

A grand opening or open house is one of the few times a practice invites the public inside before anyone is a patient. Neighbors tour the rooms, referring offices meet the clinicians, and current patients see the new space. An event plan built on free food, giveaways, a prize drawing, a sign-up sheet and follow-up texts runs into health care rules that a restaurant or a retail store does not face. This guide walks through the open house from the first announcement to the week after: what to put on your Google Business Profile before you open, how the federal beneficiary inducement law and the OIG nominal value policy apply to food and giveaways, when a door prize becomes a lottery question, what changes when the guests are referring physicians, and what permission you need to text guests afterward.

Two related topics have their own guides and are not repeated here. Free screenings, sign-in sheets at a table and results handling are covered in our guide to health fair and screening event marketing. Photo releases and HIPAA authorization for patient images are in our guide to patient photo consent for marketing. Lunches, holiday gifts and the yearly tracking log for referring physicians are in our guide to gifts and meals for referring physicians. Spreading the word with flyers, door hangers and neighborhood app posts is covered in our guide to door hangers, flyers and neighborhood apps. Permits, ADA room signs and wording for the new sign itself are in our guide to medical office signs.

This is general information, not legal advice. Raffle, sweepstakes and gaming rules, and the professional rules for physicians and other licensed clinicians, are set state by state. Sources cited were checked on October 30, 2026: 42 U.S.C. 1320a-7a, 42 CFR 1003.110, the OIG Policy Statement Regarding Gifts of Nominal Value (December 7, 2016), 42 U.S.C. 1320a-7b(b), 42 U.S.C. 1395nn, 42 CFR 411.357(k), 18 U.S.C. 1302 and 1307, 47 CFR 73.1211, 45 CFR 164.501, 47 CFR 64.1200, 16 CFR 465.4, Google Business Profile Help, and 15 U.S.C. 45 and 52.

Before the doors open: your Google Business Profile

The first place neighbors look for a new office is the map listing, so set it up before construction ends. Google Business Profile Help says a business that has not opened yet can create a profile and set a future opening date. Only the year and month are required, and the date can be up to one year in the future. After you enter the date and verify the business, the profile shows up on Google 90 days before the opening date, and during that window you can use posts, photos and the business description to announce the opening.

Two details from the same page affect the event plan. Once the business opens, the profile shows a Recently opened tag for 90 days. And until the business is officially open, users cannot suggest edits or post content such as reviews or photos on the profile. So an open house held before the official opening date is not a moment to ask guests for reviews; the profile will not accept them yet.

Keep the posts accurate. Google’s help page mentions sharing an opening day discount or coupon in a post. In health care, a discount offered to the public reaches Medicare and Medicaid patients too, which brings in the rules in the next section, and any price claim has to be true under 15 U.S.C. 45 and 52. A post that names the services you will offer, the hours and the clinicians who will see patients is safer and more useful than a coupon.

Before the sign goes up, settle the name. Our medical practice branding guide covers choosing a name and logo, trademark searches and Google Business Profile name rules.

Food, giveaways and the beneficiary inducement law

Your guests will include people with Medicare or Medicaid. Under 42 U.S.C. 1320a-7a(a)(5), a person who offers or transfers remuneration to an individual eligible for Medicare or a State health care program, and who knows or should know it is likely to influence that individual to order or receive covered items or services from a particular provider, practitioner or supplier, is subject to civil monetary penalties. Under 1320a-7a(i)(6), remuneration includes transfers of items or services for free or for other than fair market value. The regulation at 42 CFR 1003.110 uses the same definition.

The OIG Policy Statement Regarding Gifts of Nominal Value, dated December 7, 2016, explains how the office reads that law for inexpensive gifts. Congress intended that inexpensive gifts of nominal value be permitted, and the OIG interprets nominal value as a retail value at or below a per-item limit and an annual per-patient aggregate limit set out in the statement. The items may not be cash or cash equivalents. If a gift is at or below those limits, it need not fit an exception. The statement says the OIG will monitor the limits and announce any future increases, so check the current statement on the OIG site before you order anything.

What that means for an open house:

Refreshments. Light food and drinks served to everyone who walks in are a gift to each guest. Judge them by retail value per person against the policy statement, and keep them modest.
Branded items. Pens, water bottles and tote bags are gifts. Count their retail value per item, not what you paid in bulk.
Gift cards. The policy statement does not cover cash or cash equivalents, and a gift card spends like cash at the store that issues it. Leave gift cards out of a public health care event unless counsel has reviewed them.
Free services. A free consultation, a free first visit or a free procedure offered at the event is a transfer of services for free under 1320a-7a(i)(6). Screenings at an event table are covered in the health fair guide linked above. Do not offer free services on the condition that the guest books a paid visit.
Annual totals. The aggregate limit counts gifts to one patient across a year, so the grand opening tote bag counts toward the same total as a later holiday gift or a birthday card with a coupon.

The statute also lists exceptions in 1320a-7a(i)(6), including remuneration that promotes access to care and poses a low risk of harm as the Secretary designates by regulation, and retailer rewards offered on equal terms to the general public regardless of insurance status and not tied to Medicare or Medicaid services. These exceptions have conditions, and a grand opening giveaway does not fit them by default. If a planned item exceeds the nominal value limits, ask counsel which exception, if any, applies before the event, not after.

Door prizes and drawings

A prize drawing adds two separate questions: the beneficiary inducement law above, and lottery law.

On the health care side, a prize is a transfer of an item for free. A drawing where the prize has a retail value above the nominal value limits, open to guests who include Medicare or Medicaid beneficiaries, sits outside the policy statement. A prize that is itself a health care service, such as a free treatment package, is a transfer of services and raises the same issue. Keep prizes low in value, keep them unrelated to services that Medicare or Medicaid pays for, and never require a booked appointment to enter.

On the lottery side, federal law treats the mail and broadcasting separately from state law. Under 18 U.S.C. 1302, it is a federal crime to knowingly mail a circular or any publication containing an advertisement of a lottery, gift enterprise or similar scheme offering prizes dependent in whole or in part on lot or chance. Under 18 U.S.C. 1307(a)(2), those provisions do not apply to information about a lottery or similar scheme that is authorized or not otherwise prohibited by the State in which it is conducted, and that is conducted by a not-for-profit or governmental organization, or as a promotional activity by a commercial organization that is clearly occasional and ancillary to its primary business. For broadcast stations, 47 CFR 73.1211(b) describes the elements the FCC looks for: a prize, selection dependent in whole or in part on lot or chance, and a requirement to furnish money or another thing of value to compete. Whether your drawing is a permitted promotion, a regulated raffle or a prohibited lottery is decided under your state’s law, so check before you print the entry slip, and before a mailed invitation mentions the drawing.

Two plain rules help. Do not charge for entry or tie entry to a purchase or a paid visit. And do not tie entry to a review: under 16 CFR 465.4, providing compensation or other incentives in exchange for, or conditioned on, consumer reviews expressing a particular sentiment is an unfair or deceptive practice.

Inviting referring physicians and other referral sources

An open house for referring offices is a different event with different rules, even if it happens the same evening.

The federal anti-kickback statute, 42 U.S.C. 1320a-7b(b), makes it a crime to knowingly and willfully offer or pay any remuneration, directly or indirectly, in cash or in kind, to induce a person to refer an individual for items or services paid for in whole or in part under a Federal health care program. A reception for referral sources is remuneration in kind. Keep it modest, offer it to a group rather than to selected high referrers, and keep it separate from any discussion of referral volume.

If your practice or facility furnishes designated health services, the physician self-referral law, 42 U.S.C. 1395nn, applies too. The list in 1395nn(h)(6) includes clinical laboratory services, physical therapy, occupational therapy, radiology and imaging, radiation therapy, durable medical equipment, home health services, outpatient prescription drugs, hospital services and outpatient speech-language pathology. The nonmonetary compensation exception at 42 CFR 411.357(k) allows items or services, not cash or cash equivalents, up to an annual aggregate limit per physician that CMS adjusts for inflation each year and posts on its physician self-referral website. The compensation may not be determined in any manner that takes into account the volume or value of referrals, and it may not be solicited by the physician or the physician’s practice. Track the value of the event per physician guest, and count it against that physician’s annual total alongside any other meals or gifts.

Inviting current patients and following up with guests

Your patient list is the easiest audience for an open house invitation, and HIPAA decides how you use it. Under the definition of marketing in 45 CFR 164.501, a communication that describes a health-related product or service provided by the covered entity making the communication is not marketing, unless the covered entity receives financial remuneration for making it. An invitation to see your own new office and meet your own clinicians fits that description. The analysis changes when a sponsor is involved: if a vendor, a device company or another business pays you or covers the event in exchange for being promoted in the invitation, the financial remuneration exception no longer applies, and the communication becomes marketing that needs the patient’s written authorization. Keep sponsors out of patient invitations, or get counsel’s view first.

Guest follow-up is the other half. A sign-up sheet that asks for phone numbers so you can text event offers later needs the right consent. Under 47 CFR 64.1200(a)(2), a call that includes or introduces an advertisement or constitutes telemarketing, made with an automatic telephone dialing system or an artificial or prerecorded voice to a mobile number, requires the prior express written consent of the person called, with exceptions listed in the rule. Under 64.1200(f)(9), prior express written consent is a signed written agreement that clearly authorizes the seller to deliver those messages to a specific number, and it must disclose that the person is not required to sign as a condition of purchasing any goods or services. Signature includes an electronic signature where valid under federal law or state contract law. Put that consent on its own line or form, not inside the door prize entry, and see our guide to text message appointment reminders for how reminder texts differ from promotional ones.

Photos are the last loose end. Guests who are patients may appear in event photos that end up on social media. The photo consent guide linked above covers when a HIPAA authorization is needed and how to handle guests who do not want to be photographed.

Illustration: two ways to run a grand opening

Illustration: [Practice name] mails every patient on file and every household in [county] an invitation that promises a free first visit for anyone who books at the event, a drawing for a tablet computer, and gift cards for the first guests through the door. A local device company pays for the catering and its logo is printed on the patient invitation. At the door, guests write their phone number on the drawing slip, which says winners agree to receive offers by text. The practice asks winners to leave a five-star review that night.

Illustration: [Practice name] sets an opening date on its Business Profile months ahead and posts construction photos and the list of services. The patient invitation describes the new office and the clinicians, with no sponsor. Guests get light refreshments and a branded water bottle, both valued against the current OIG policy statement. The drawing has a small prize unrelated to any service, no entry fee and no appointment condition, and counsel has checked it against state law. A separate optional form collects text consent with the not-a-condition disclosure. A later evening for referring offices is logged per physician against the self-referral exception, and event photos include only people who agreed to them.

Checklist

Create the Business Profile with a future opening date, verify it, and use posts to share services and hours rather than coupons.
Value food, gifts and prizes at retail, per guest, against the current OIG nominal value policy statement.
Leave cash, gift cards and free services out of a public event, and never tie a gift to booking a paid visit.
Check the drawing against state raffle and sweepstakes law, with no entry fee and no purchase condition.
Do not mention a drawing in mailed invitations until counsel has confirmed it is permitted.
Never tie a prize or a discount to a positive review.
Run any referring physician event separately, keep it modest, and log its value per physician if you furnish designated health services.
Keep sponsors out of invitations sent to your patient list unless counsel has reviewed the authorization question.
Collect text consent on its own form with the required disclosure, not on the drawing slip.
Follow the photo consent guide for anyone who appears in event photos.

Planning a giveaway beyond the event itself, such as an online sweepstakes? Our giveaway and sweepstakes guide covers free entry, official rules, state filing and bonding, and announcing the winner.

How we help

We build websites, local search, Google Ads and AI front desk tools for independent practices and health businesses. For a new office or a grand opening, that means a Business Profile set up before you open, a website with a clear opening page, services and directions, event pages that state what guests receive, and sign-up flows that keep text consent separate from everything else. We do not decide whether a gift, prize or event fits the federal rules or your state’s law; your counsel does. 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. We do not sell lead lists and we do not pay for referrals. For the wider rules, see our healthcare marketing rules hub.

Can we serve food at our open house if Medicare patients attend?

The OIG reads the beneficiary inducement law in 42 U.S.C. 1320a-7a(a)(5) to allow inexpensive gifts of nominal value, as defined in its December 7, 2016 policy statement. Judge refreshments by retail value per guest against the current limits and keep them modest.

Can we give away gift cards at a grand opening?

The OIG nominal value policy statement says the items may not be cash or cash equivalents, and a gift card spends like cash at the store that issues it. Leave them out of an event open to Medicare and Medicaid patients unless counsel has reviewed them.

Is a door prize drawing legal at a medical office?

It depends on your state’s raffle and sweepstakes law and on the prize. Keep the prize low in value and unrelated to covered services, charge nothing to enter, do not require an appointment, and have counsel check it before any mailed invitation mentions it, because 18 U.S.C. 1302 restricts mailing lottery advertisements.

Can we ask open house guests to leave a review?

Google Business Profile Help says users cannot post reviews on a profile until the business is officially open. After that, never tie a prize or discount to a positive review, which 16 CFR 465.4 treats as an unfair or deceptive practice.

Do we need patient authorization to invite patients to our open house?

Under 45 CFR 164.501, a communication describing your own health-related services is not marketing unless you receive financial remuneration for it. If a sponsor pays to be promoted in the invitation, the communication becomes marketing that needs written authorization.

Can we text guests who gave us their number at the event?

For promotional texts sent with an automatic dialing system, 47 CFR 64.1200 requires prior express written consent that says signing is not a condition of purchase. Collect it on a separate form, not on a drawing slip.

Medical office grand opening and open house rules: gifts, raffles, invitations and follow-up