The bought-lead model has a federal problem
The Eliminating Kickbacks in Recovery Act, 18 U.S.C. 220, passed in 2018 and made it a federal crime to pay or receive remuneration for referring a patient to a recovery home, clinical treatment facility, or laboratory. Unlike the Anti-Kickback Statute, EKRA applies regardless of payer, so cash-pay and commercial insurance are both in scope.
The part that catches marketers is compensation structure. Paying a marketer per lead, per admission, or as a percentage of revenue is the pattern prosecutors have charged. A fixed fee for defined work is the safer structure, and it is how we contract.
We are a marketing agency, not your counsel. Have your healthcare attorney review any lead arrangement before you sign it. What we will tell you now is that we will not write you a per-admission contract.
Shared leads arrive already worked
A purchased lead is frequently sold to three or more facilities. By the time your admissions coordinator calls, the family has already been called twice, and the person who called first has the relationship.
Cost per lead looks good on that invoice. Cost per admission rarely does, once you divide by a close rate that competitors working the same phone number have already cut.
What an owned channel consists of
Search rankings on level-of-care and location pages. A Google Business Profile per address with recent reviews. Paid search on high-intent terms where the account is certified and geographically tight. A site where the phone number is visible on every screen and the click-to-call works on a phone held in a hospital parking lot.
None of that is exotic. It is ordinary work most facilities have half-finished, which is why call volume swings so far between facilities of the same size.
Referrals are a channel, and your name search decides whether they close
Interventionists, detox facilities, sober living operators, hospital discharge planners, and therapists send patients. Those relationships are not marketing spend, but they are a channel, and they live or die on what someone finds when they search your name after being handed your card.
We treat your brand SERP as part of lead generation. Current reviews and an accurate profile close referrals that otherwise stall on a bad first impression.
Counting the thing that pays you
A lead is not an admission and a form fill is not a lead. We put call tracking on every channel so each ring carries its source, then work with your admissions team or CRM to attach the outcome.
The number we report is calls, qualified calls, and admissions by source. When a channel stops producing admissions we cut it, even if it is still producing leads.