Governance

What data this program touches

The program works from two things: the public federal provider registry — the CMS NPPES data that lists who practises where and in what specialty — and business contact details for clinical practices. Office addresses, practice names, specialties, whether a practice is currently active. The same information a colleague would use to send someone a referral.

It touches none of the following, at any point: patient names or identifiers, clinical records, appointment data, claims or billing data, diagnoses, or anything a patient has told a clinician.

That is not a policy we promise to follow. There is no field for patient data to live in, and that absence is enforced at four independent layers of the system. A policy can be forgotten under deadline pressure; a column that does not exist cannot be filled.

Do you need a BAA?

No — and it is worth being precise about why, because “no” is the answer a careless vendor gives too.

A business associate agreement governs a vendor’s handling of protected health information. This program never receives protected health information, so there is nothing for such an agreement to govern. The obligation does not arise, rather than being waived.

If your counsel or your own compliance posture wants one on file regardless, we will sign it. But read the architecture first. A BAA covering a system that has no patient fields is paperwork rather than protection, and paperwork is not what should make you comfortable here. The absence of the fields is.

If your situation genuinely requires patient-level targeting, this is the wrong product, and we would tell you that on the first call rather than after the setup fee.

Why we never pay for referrals

Our fees are flat: a setup fee and a monthly retainer. Never a percentage, never a fee per referral, never anything that rises when a clinician sends you a patient.

This matters more in referral marketing than almost anywhere else. Volume-linked compensation around clinical referrals is the structure that federal anti-kickback rules exist to prevent, and for behavioral-health practices in particular, the professional codes are stricter and closer to hand than the federal statutes. The ACA code prohibits fee splitting and referral remuneration outright (A.10.b). The APA requires that payments between professionals reflect services actually provided rather than the referral itself (Standard 6.07). Several states, North Carolina among them, prohibit referral fees by statute. We cite these because they are the rules your licensing board applies to you; we are describing the structure we build to, not offering you a reading of your obligations.

We do run a referral credit for practices that introduce us to other practices — half the setup fee, in invoice credit, each way. That is one business referring another business to a marketing vendor, it is paid in credit rather than cash, and it never involves a clinician being compensated for sending a patient anywhere. The two are different in kind, and keeping them visibly separate is the point.

Two details of that credit are deliberate and worth stating, because they are the same distinctions we hold clients to. What you earn is set by the plan you are already on, not by the plan the practice you referred chooses — so nobody is paid more for steering someone into a larger contract. And it is credit against your own invoices rather than cash, which keeps it a discount on a commercial relationship instead of a payment for an introduction.

The gates before anything mails

Two human approvals, both of which can stop the program:

Your own attorney reviews the packet. We do not supply the lawyer, and nothing we produce is “legally cleared” or “compliant” — those are judgments that belong to your counsel, which is exactly why the gate exists. What we produce is attorney-ready: a package assembled for a lawyer to read efficiently.

You sign off clinically. Nothing goes out over your name that you have not read.

Underneath both, three structural rules. A claim about your practice prints only if it has been verified against a certificate or a board lookup — the registry is default-deny, so a fact that is true but unverified does not print. The document your attorney reviewed is provably the document that mails, because the renderer reproduces it byte for byte. And no wave can spend your money without an explicit approval; the tooling cannot bill a print run on its own initiative.

No language model participates in any compliance decision or send decision. The gates are deterministic rules, because a gate whose behavior varies run to run is not a gate.

Suppression

Your list of people who must never be mailed is honored from the first wave. Not as a filter applied at send time that someone could bypass, but as part of what makes a record mailable at all.

What this site does

This site sets no cookies, loads no advertising or social pixels, and runs no third-party tracking scripts. There is no form on it. The scheduler is a Calendly link that opens on Calendly’s own site — that is a third party and it does collect what you type into it, which is worth stating plainly rather than leaving you to discover.

Analytics are aggregate page counts, cookieless, with no cross-site identifiers.

The reason is not fastidiousness. Federal regulators have spent the last several years warning health systems about exactly this — third-party trackers on healthcare properties leaking information about who visited what page. A vendor selling careful data handling should not be running the thing regulators are writing letters about. The rule is enforced by a build gate, not by our good intentions: a tracking script added to this site fails the build.

Accessibility

This site is built to be usable without JavaScript, with semantic headings, visible focus states, and colour contrast handled in the design tokens rather than page by page.

We have not commissioned a formal WCAG audit, so we do not claim a conformance level we have not tested. If accessibility conformance is a procurement requirement for you, raise it on the call and we will scope an audit properly.

Claims and evidence

Every claim on this site is registered in a proof inventory with its status and its evidence, and the build refuses to publish a figure that is not in it. Claims are upgraded by amending that inventory first and the page second, never the other way around — the same discipline the program applies to a client’s own claims, applied to ourselves.

We are taking a limited number of practices into a first cohort. If you want to be one of them, book a call.