Compliance

Built to pass your compliance review.

If your compliance officer is joining the first call, this page was written for them.

HIPAA · BAA

We sign the BAA before we see a single record.

Every program that touches patient information starts with a business associate agreement. Our callers work in the United States, so your patients' records stay here. A breach at an offshore vendor would still be your liability, which is why we don't use one.

Refill reminder exception

Refill calls stay inside HIPAA's refill reminder exception.

We call about the medication the patient is already taking and nothing else. That is what keeps a refill reminder a permitted communication rather than marketing.

42 CFR 410.38

Every resupply order has a documented refill request behind it.

Medicare requires a documented request from the patient before DME supplies are resupplied. Our script captures it on every call and records it the way the rule requires, so your claims have the documentation to support them.

TCPA

We dial by hand and we stop when a patient asks.

Consent to call is captured at onboarding and logged. When a patient asks us to stop, we stop on that call and record it.

Controlled substances

Controlled substances are excluded from every program.

We do not make refill, adherence, or reminder calls about controlled substances for any client, under any pricing.

Flat fees · Anti-kickback

We are paid for the work, never for the order.

Fees are fixed for a defined program: per enrolled patient, per call, per campaign, or per block of hours. Never per order, per refill, or a percentage of anything. There is no financial reason for us to place an order that shouldn't be placed and your compliance officer can confirm that in the contract.

Nurse licensure

Clinical calls are made by licensed RNs and LPNs.

Oklahoma belongs to the Nurse Licensure Compact, so one multistate license covers 40 states. Triage, post-discharge, and care management calls are handled by nurses licensed for the patient's state, against a standardized protocol, with every decision documented.

What we don't do

Work we turn down on principle.

  • Fundraising and donor calls
  • Anything paid as a percentage of orders, refills, or money raised
  • Calls about controlled substances
  • Offshore callers

Want our BAA and calling policy before the first call?

Just ask. We'd rather your counsel read them now than after the proposal.