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Q&A on Purchasing Leads: On the Government's Radar
By Jeffrey S. Baird, Esq.
Lead generation companies are coming out of the woodwork. While they have been around for years in the non-healthcare industries, they have recently been entering the health care sector, including HME. While there are relatively few legal restrictions pertaining to lead generation in non-healthcare industries, the same is not true with health care. In particular, in purchasing leads, HME providers must be careful not to violate the Medicare anti-kickback statute, the telephone solicitation statute, and Supplier Standard No. 11.
A lead generation company compiles leads in different ways. It may manage a number of websites, and have Medicare beneficiaries who are customers input their names, addresses and phone numbers. Or a lead generation company may advertise by newspaper, radio or TV and have beneficiaries call a toll-free number. The lead generation company will then mail them promotional literature, along with a stamped, self-addressed post card that beneficiaries can fill out and mail back. A lead generation company can also purchase leads from a “lead broker.” For reasons discussed later, I do not like the concept of purchasing leads from brokers. This Q & A focuses on how leads can be generated and purchased.
QUESTION: Your title says that purchasing leads has made its way on the government’s radar. What do you mean by that?
