Letter: Not all fees are bad
It is important to clearly understand the companies program that is being responded to in order to understand the OIG's stance (See "OIG frowns on pay-to-play arrangement" on page 4). The program mentioned basically sends out an electronic or fax notice that a patient is being discharged from a hospital and that other services are needed by the patient. Since those providers that are signed up electronically would possess an unfair advantage over those that receive faxes, this is the key element of the problem with this program. It is not the fees associated. Every pharmacy today that receives an electronic prescription must pay a transaction fee. These programs have been around for a long time and pose no violation to the anti-kickback statute. Make sure that you do not take the answer provided by the OIG out of context.
-- Mickey Letson, CEO, Dream Software