Frontrow Health takes liability/regulatory issues seriously and has designed its model to be compliant with federal and state regulations in partnership with industry-leading regulatory advisors.

01 | Liability

Liability control: Patients accept terms and conditions that acknowledge their provider is not responsible for any adverse events related to a product the patient purchases through the provider’s digital store.

Impact: Patients acknowledge their provider is working in good faith and that it’s not possible for them to know every potential side effect of each product given they react differently to each unique person.

Liability control: Providers are never prescribing treatments through the platform.

Impact: By including an OTC consumable, device, etc., on your store, you are educating them about how this product seems like a potentially beneficial product that may be worth checking out — you are never specifically prescribing a product to your patient or recommending that a patient should be taking a specific product as a part of a unique treatment plan.

Liability control: The patient purchases the product on the health brand partner’s website; the patient never actually purchases anything on a provider’s storefront.

Impact: If for some reason the patient is given a bad batch of a product, etc., because the provider never handled the product and the purchase happened between a consenting person and the health brand, liability remains on the health brand.

02 | Regulatory

From a regulatory perspective, we follow Anti kick-back and Stark Laws to the letter. As a refresher, these laws instruct that providers can not receive compensation for referring a patient to a service that is reimbursable by Medicare or Medicaid (Anti kick-back), or cannot receive compensation for referral of Medicare or Medicaid beneficiaries (Stark).

For that reason, you will not be paid for any clicks from patients who are Medicare / Medicaid beneficiaries, for clicks related to products that are reimbursable by Medicare or Medicaid, OR (to be hyper-cautious) could be reimbursable by private insurers. (We only have a few products that meet any of the above qualifications anyway, but in the case you do add them to your store, you will not be compensated for any clicks related to these products).

Additionally, we go above and beyond to ensure we also follow the spirit of the law which is to ensure providers are never making bad decisions for their patients purely for the sake of financial reward. For this reason, we’ve applied the following critical regulatory controls:

Regulatory control: Providers are paid regardless of whether the patient buys the product.

Impact: Providers are not incentivized to “sell” any products for financial gain, just to educate their patients on products that could be relevant and beneficial for them.

Regulatory control: Providers are paid a flat $2 fee per product click, not a percentage of the retail price of the product.

Impact: Providers are not incentivized to include products that are more expensive in an attempt to gain more financial reward.

Regulatory control: Providers are paid the same flat fee per product clicked (vs. higher flat fees for some products).

Impact: Providers are not incentivized to include products that have higher fees if all fees are the same.

Regulatory control: Providers are paid by Frontrow, not the product manufacturer

Impact: There is no financial relationship between the manufacturer and and the provider, we partner with the provider, we pay them the same flat rate and the brands have no influence over how or how much our providers partners are paid.

In summary, through Frontrow, there is no benefit for a provider to guide patients to products they don’t like because providers can add any health product to their store, and all click payments are the same, so why add products you don’t think are good? And again, we pay providers for clicks and for educating their patients, not for “selling” — there is no benefit to the provider when the patient buys any product.