I got it. Copy & Paste works well.

The Q&A about promotional items gives a definition of "nominal value". It
describes pens, note-pads, cups with a logo, toothbrush, floss and
toothpaste.

I think a large plastic tote bag (my estm $10 US) with a can of powder
(estm $8 US) or several RTF bottles (estm $1-2 US each) and a couple of
single packets of powder, plus a CD of baby-calming music (estm $16-18(US),
a book that would sell for $13(US) in a bookstore, a small insulated bag
with freezer gel packs, etc. I think we're pushing $40-50(US) retail value
if all these things are in there.

By most ethics definitions, "nominal value" is about $25. per year.

I think you can still argue in your Committee that this promotional package
is NOT of nominal value and therefore excluded under HIPAA rules.

Phyllis

--- Phyllis Adamson, IBCLC
--- Glendale, AZ, USA
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