As part of a new policy in Florida, any entity—third party or in-house—that does any form of marketing for your addiction treatment center must be licensed by the state. The consumer services department posted the application but isn’t ready to begin accepting the completed paperwork yet, according to Jeffrey Lynne, a lawyer who has been involved in the collaboration efforts to eliminate fraud and patient brokering.
Lynne told me via email that licensing is required for entities doing “any form of marketing for the purposes of enticing a potential customer to patronize a treatment center or recovery residence, either directly, or indirectly.” And that includes call centers and any organization that provides online, radio or television advertising from Florida, to residents of Florida, or targeting potential customers to patronize Florida-based treatment centers or recovery residences.
The application appears to be pretty thorough, and there are a few things that I found interesting. See what you think.
- Applicants must disclose all “doing business as” (DBA) names so they won’t be able to hide behind a web of affiliations to avoid discovery.
- Career criminals could be squeezed out early because all the principal officers, directors and other top execs are required to provide personal information for background checks, including disclosure of previous, related arrests and convictions.
- Monitoring and enforcement could be increased because all locations and phone numbers from which the applicant is doing business must be listed.
- Scripts that salespeople will use must be provided.
- Written materials that will be sent to prospective customers must be provided.
- The account numbers of the marketing entities’ banking institutions are required—I assume this will be helpful should anyone need to “follow the money.”
- The application processing fee is $1,500, which doesn’t seem to be an over-reach considering the situation.
This matters to every treatment center—even the ones outside of the Florida market. Why? Because as I’ve said before, the patient brokers that have done so well in Florida could easily move base camp to your state now that Florida has become so unfriendly. In that case, your state might look to this new licensing policy as model for adoption.