We have, unfortunately, spent quite a bit of money to put a legal framework in place. Our operating model is slightly different than Workpath/Iggbo, so a number of the concerns in the piece don't apply. I don't want to give too much away b/c the framework we've developed is a competitive advantage.
Health professional quality, HIPAA adherence and data privacy are part of our core mission. They're first-class citizens both in our legal and product/technology frameworks.
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While you reference an interesting piece from nppn.info, I don't find their argument to be very compelling. This piece reads like exactly what you'd expect from an lobbying org looking to protect their space. It reads like a very impressive argument - only when you don't look for any alternatives. I worked in a similar space and we found solutions to nearly every problem this piece lists.
Since this doesn't seem to be their angle, that means they are contracting with labs, which means small scale regional providers, because generally LabCorp and Quest aren't interested in partnering with startups. Maybe they had a breakthrough here?
As an API service, their main customers would likely be the on-demand telemedicine startups (Nurx, DoD, Eden, many others.... However, they all are either narrow-service and national (Nurx, Roman; which have their own issues) or comprehensive and regional.
So that means they either can't operate legally (sketchy), have to do the work of cobbling together regional provider networks and clients that want those service areas covered (doable, but hard), or have scored a breakthrough with a big lab company or network that's a hidden advantage we don't see here.
Just interested in what they've found that can get them going in a tough space.
There's a slight chance that this sort of service may in fact be illegal, or at least in a gray area, depending on who performs the sample draw: https://nppn.info/index.php/blog/view/iggbo-is-illegal
Typically, if you order a test, the person performing the test has to be actually employed by the organization that pays them (ie, cannot be a contractor), and there aren't national-level service providers for things like phlebotomy, because the economics don't really work out yet.
Also, if the provider (MD/NP/PA) service isn't actually doing the test themselves, then I believe they have to provide the option to the patient to choose what service they go to (Lab Corp, Quest, your service or another) because not providing the customer a choice may violate Stark law prohibitions on inter-provider referrals.
I am sure you have considered much of this, but would love to hear what you've found so far.