Billing & compliance

Every integration on this surface is bring-your-own — you hold the vendor contract, you hold the key, the vendor bills you, and neolife earns nothing on the transaction. There is a second billing mode in the data model. It is locked, it is visible in the product as locked, and for one of the four categories no amount of paperwork unlocks it.

This page explains why, because "we don't do that" is not an answer a compliance officer can take to their board.

This is not legal advice. It is a description of how the product behaves and the reasoning it was built on. Your obligations depend on your structure, your payor mix, and your states. Talk to your own counsel.

The two modes#

	BYO — ships	Managed — locked
Vendor contract	Yours	neolife's
API key	Yours	neolife's
Who the vendor invoices	You	neolife
What you pay neolife	Your flat platform fee. Unchanged	Vendor cost + a documented flat margin
Metered on the vendor transaction	Nothing	Per unit

Nothing is metered on a BYO vendor transaction. Not zero-rated — absent. The lab and consult paths write no usage event at all, so there is no dormant counter that a configuration change could later start billing from. An unbuildable shape beats a disabled one.

Why managed is locked, not just unbuilt#

Managed billing requires three gates that are deliberately independent, because they have different owners and different failure modes.

Gate 1 — the vendor's contract permits resale. A commercial fact, taken from the signed agreement, recorded with a reference to it. Not a free-text assertion.

Gate 2 — counsel has cleared it, with a fair-market-value basis document and a memo on file.

Gate 3 — you opted in. Your choice, refused unless gates 1 and 2 already pass.

They're separate because collapsing them makes "this vendor forbids resale" indistinguishable from "nobody has asked legal yet." Those are different problems with different next actions, and a single boolean would hide which one you have.

And there is no percentage margin field anywhere in the system — not disabled, not gated, absent. Every vendor category here is clinical. A percent-of-cost markup on a clinical service tracks the value of the clinical act: a basic panel runs about $30 and a comprehensive one about $300, so a 20% markup earns $6 on one and $60 on the other. That is income that rises with how much medicine gets ordered. A flat cents-per-unit margin doesn't move when a clinician orders the bigger panel, which is the entire point.

Labs: the prohibition that paperwork doesn't lift#

For lab connections, managed mode is refused regardless of every gate above. A fully counsel-approved configuration with an FMV basis and a memo on file still fails, because the refusal isn't a gate — it's a prohibition, and it's checked before the gates are.

EKRA — the Eliminating Kickbacks in Recovery Act, 18 U.S.C. §220 — makes it an offence to pay or receive remuneration in exchange for referring a patient to a laboratory. The detail that matters here: EKRA is all-payor. Unlike the Anti-Kickback Statute, it has no carve-out for cash-pay business. A cash-pay clinic gets no shelter from it, and neither does a cash-pay platform.

Taking a margin on a lab transaction is remuneration that scales with lab referrals. That's the shape EKRA describes, and there's no volume of memos that changes what the shape is. So the category itself refuses it: the schema rejects a lab connection in managed mode for every approval state, and the lab order path writes no usage event to bill from.

Pharmacy connections are locked the same way for the parallel reason — pharmacies connect free and are never rebilled.

AKS, in plain language#

The Anti-Kickback Statute (42 U.S.C. §1320a-7b(b)) prohibits knowingly paying or receiving anything of value to induce a referral for an item or service reimbursable by a federal healthcare programme. Unlike EKRA it has a federal-programme hook, which is why cash-pay posture is relevant to AKS and not to EKRA.

Three things follow, and they're visible in how the product behaves rather than only in a policy document.

neolife's fee never varies with clinical volume at a vendor. Your platform fee is flat. Order one lab panel this month or four hundred; the number doesn't move. A fee that rose with diagnostics ordered would be remuneration that tracks referrals.

neolife never selects a vendor for you on a fee basis. Routing follows your clinical and operational rules. There's no fee-based steering, no auction of your fill, and no rebate from any vendor — the connection carries an explicit flag asserting no steering, and it can only be false.

neolife is never paid by a vendor. Not a per-connection fee, not a revenue share, not a marketing payment tied to volume. Vendors pay nothing to be connectable. A platform earning from both sides has an interest in where your clinical work goes.

The order rail is priced the same way for the same reason — a flat platform fee plus a flat per-order fee, never a percentage of the drug price. Published, not negotiated. A spread has to hide; a flat fee can be printed.

What this looks like in the product#

The managed option renders as a locked card with the reason inline, not a hidden feature and not a greyed button with a tooltip. You can read exactly which gate is unmet and who owns it — partnerships for the contract term, counsel for the clearance, you for the opt-in — and for labs you can read that the category itself refuses it.

That's deliberate. A compliance boundary you can see and understand is worth more than one enforced invisibly, because it's the version you can hand to your own counsel and have them check our reasoning.

Rule: BYO is the shipped mode for every category. Managed is locked for the other two pending counsel, and structurally impossible for labs and pharmacies. Neither statement depends on UI discipline — both are enforced in the schema, before anything is persisted.

Next steps#

• Labs — the surface this posture governs most directly.
• Provider networks — why neolife doesn't pick your clinician either.
• Integrations overview — the connection lifecycle and the flags.