Required Disclosures regarding Administrative Fees earned by PAS

Background

The safe harbor regulations under the Anti Kickback Statute define payment and business practices that will not be considered kickbacks, bribes, or rebates that unlawfully induce payment by Medicare or Medicaid programs. The regulations specify allowable financial and referral relationships between physicians or other providers and suppliers.

Under the safe harbor regulations, PAS is allowed to receive administrative fee payments from vendors based on the percentage of the purchase price of goods or services provided by the vendor, subject to certain conditions.  PAS is required to disclose to each member annually the amount of fees received from each vendor with respect to purchases made on behalf of the member.

Disclosures

In connection with PAS Services Purchase Agreement with the following suppliers, PAS received the following Contract Administrative Fees:

FY19 (October 1, 2018 through September 30, 2019): $95.13 from Preferred Billing Associates, LLC

FY20 (October 1, 2019 through September 30, 2020): $1,752.27 from Preferred Billing Associates, LLC

FY21 (October 1, 2020 through September 30, 2021): $4,379.58 from Preferred Billing Associates, LLC and $153.55 from StratX IT Solutions, LLC