Where Are the Compliance Lines in Toxicology Testing?
For healthcare organizations and professionals (B2B) · Physician-led · Updated 2026-07-12 · CLIA #45D2048957 · CAP #8722734
Testing must be ordered on medical necessity — not on volume, and never in exchange for anything of value.CLIA #45D2048957 · CAP #8722734 · Same-day results · Walk-ins welcome
They are well documented, and the enforcement history in this sector is extensive. The Anti-Kickback Statute prohibits offering or receiving anything of value to induce referrals. The Stark Law restricts physician self-referral for designated health services. And medical necessity governs frequency: routine, undocumented, blanket definitive testing of every patient at every visit is precisely the pattern that draws enforcement.
What we will not do
| Practice | Our position |
|---|---|
| Paying for referrals, per-test or otherwise | No. Not in any form |
| Revenue sharing with referring providers | No |
| Free staff, equipment or supplies as an inducement | No — supplies are provided consistent with FMV and applicable rules |
| Blanket reflex confirmation of every analyte, every visit | No — reflex protocols are defined on clinical criteria |
| Waiving copays to attract volume | No |
A laboratory that offers you something of value in exchange for your specimens is not offering you a partnership. It is offering you exposure to federal liability.
What a defensible program looks like
An individualized, documented rationale for testing; a frequency justified by risk and clinical status; definitive confirmation where it will change a decision; and a panel built on medical necessity rather than on billable-analyte maximization. ASAM and the CDC opioid prescribing guideline are the reference points.
FAQ
- Do you pay for referrals?
- No. Not per specimen, not per test, not indirectly.
- Can you provide collection supplies?
- Yes, consistent with fair market value and applicable rules — onboarding.
- Who determines test frequency?
- The ordering clinician, documented and individualized. We do not tell you to test more.
- Can we set reflex rules?
- Yes, defined on clinical criteria — see custom panels.