Healthcare compliance isn't a peripheral concern in specialty diagnostics. It's a structural one — and it has to be built into how a collection network operates, not layered on top of it after the fact.
The Anti-Kickback Statute (AKS) and the Eliminating Kickbacks in Recovery Act (EKRA) govern how healthcare providers, labs, and intermediaries can compensate individuals or entities for patient referrals and specimen collection. For specialty labs building or expanding their collection networks, these regulations define what a legally defensible structure looks like — and what it doesn't.
MOMS was designed with this legal framework in mind from the ground up. The platform's model addresses each of the four elements that determine AKS/EKRA compliance in a specimen collection network.
AKS and EKRA both restrict financial arrangements that could induce referrals — which in a collection network context means compensating a draw site in exchange for directing patients to a specific lab.
MOMS eliminates this structure entirely. Labs and MAPs connect through the MOMS platform, not through direct contractual arrangements with each other. MOMS is the intermediary — managing the network, the compliance obligations, and the operational relationship. A MAP in the MOMS network does not have a direct financial relationship with any lab. There is no referral arrangement to scrutinize.
AKS risk is heightened when compensation to a collector or draw site is tied to the volume or value of referrals — that is, when a MAP earns more by directing more patients to a specific lab.
MOMS compensates MAPs at fair market value for collection services performed. Compensation reflects the service rendered, not the lab it flows to or the volume of specimens collected on behalf of any particular lab partner. There are no per-referral bonuses, no volume tiers that incentivize directing patients, and no financial arrangement that could be characterized as remuneration for referrals.
Both AKS safe harbors and EKRA compliance depend on documented arrangements. A network where collection relationships are informal or undocumented carries inherent regulatory risk, regardless of how the compensation is structured.
Every MAP in the MOMS network operates under a written agreement with MOMS — not with any individual lab. These agreements establish the terms of the relationship, the compensation structure, the compliance obligations, and the scope of services. The documentation is in place before the first draw happens.
A collector who influences which lab receives a specimen, or which tests are ordered, occupies a different legal position than one who collects a specimen pursuant to an existing physician order and routes it through an established chain of custody.
MAPs in the MOMS network perform collection services only. They do not order tests, direct patients to specific laboratories, or participate in any decision about which lab receives the specimen. The ordering relationship remains between the physician and the patient — MOMS and its MAPs operate at the collection layer only.
Labs building collection networks on their own — contracting directly with draw sites, structuring their own compensation arrangements, managing their own documentation — carry the compliance burden in-house. Every direct arrangement is a potential AKS/EKRA exposure point that requires ongoing legal review, documented FMV analysis, and contract management at scale.
MOMS transfers that structural risk. The platform's model is built on the legal architecture that compliant collection arrangements require. Labs connect to the MOMS network and inherit a collection infrastructure that has already been structured to meet these standards — not one they have to build themselves, and not one they have to audit every time they expand into a new market.
For specialty labs whose collection needs are growing — into new geographies, new service lines, new test types — the compliance architecture of their collection network is not a legal afterthought. It's a structural requirement. MOMS was built to meet it.
View the MOMS MAP Network coverage and explore how the platform supports your lab's collection needs: https://www.myonemedicalsource.com/map-network-coverage