Referral source

Record how the inquiry arrived

Sources include self or family referrals, clinicians, schools, plans, case managers, community organizations, directories, search, events, or campaigns. Map “referral partner” and “referral channel” to one taxonomy.

The CASP Organizational Guidelines public overview describes business, clinical, and risk-management recommendations for autism service organizations. CASP sells the detailed guidelines. The source register below is Finni's editorial operating model; the public overview does not prescribe it.

Separate these records:

A physician recommendation may be clinically relevant or satisfy a defined payer rule. Verify the member, product, current rule, dates, provider, service, and documentation. A directory click or school contact has no independent clinical or coverage authority.

Build a source register

Use a stable source ID rather than relying on spelling in free text. Record:

• source ID and category, organization, role, and approved route
• first-touch date, inquiry ID, requested service, geography, and service location
• relationship owner and agreement, effective dates, and review date
• payments, discounts, gifts, services, data exchanges, other value, and required disclosures
• authority for information received or returned
• capture method and confidence, unknown option, and attribution, duplicate, and correction rules
• source evidence, effective date, verifier, and retention location

Keep first-touch attribution separate from assisted touchpoints. Preserve each recorded touchpoint while applying the written rule consistently. This makes reporting reproducible without erasing the family's choice.

Client need and choice govern clinical referrals

The BACB Ethics Code applies to BCBA and BCaBA certificants and people who completed an application for either credential. Standard 3.13 tells covered behavior analysts to base referrals on client or stakeholder needs, include multiple providers when available, disclose provider relationships and referral fees or incentives, document referrals, and make appropriate follow-up efforts. BACB has no separate jurisdiction over organizations or corporations.

Use organization-wide choice controls. Give families accurate information about scope, availability, location, access, language, timing, payment paths, and known relationships. Avoid steering based only on revenue, ownership, friendship, reciprocal volume, or payer preference. A qualified clinician retains responsibility for clinical recommendations within their scope.

Review every exchange of value

A referral relationship can create legal risk even when the service is appropriate. HHS OIG's physician-education fraud-and-abuse overview explains that the federal Anti-Kickback Statute prohibits knowingly and willfully offering, paying, soliciting, or receiving remuneration to induce or reward referrals or other business involving items or services payable by a federal healthcare program. Remuneration includes noncash value, and the statute reaches both the payer and recipient.

Safe-harbor protection requires every applicable condition. The OIG's current fraud-and-abuse FAQ clarifies that partial compliance gives no safe-harbor protection, but failure to fit a safe harbor is not automatically illegal; risk is assessed from the total facts and circumstances, including intent. It also states that fair market value may reduce risk but does not guarantee legality.

The same FAQ separately describes the Beneficiary Inducements CMP, which can apply when remuneration is likely to influence a Medicare or State healthcare-program beneficiary's selection of a provider, practitioner, or supplier. Other federal and state anti-kickback, fee-splitting, patient-brokering, self-referral, false-claims, professional-entity, consumer, licensure, and payer-contract rules may require separate analysis. Route referral fees, lead purchases, co-marketing, free staff or space, gifts, reciprocal arrangements, and percentage-based payments through qualified healthcare counsel before launch.

Match privacy and marketing authority to the purpose

For HIPAA covered entities, HHS treatment, payment, and healthcare-operations guidance includes referral from one healthcare provider to another within the definition of treatment. The permitted pathway still depends on the parties, purpose, data, and other applicable restrictions.

Paid promotion and treatment coordination require separate analyses. For a covered entity, HHS marketing guidance generally requires authorization for PHI uses or disclosures that meet the Privacy Rule's marketing definition, subject to limited exceptions. If marketing involves direct or indirect remuneration to the covered entity from a third party, the authorization must state that remuneration is involved. HHS minimum-necessary guidance generally applies to covered uses, disclosures, and requests. Its treatment exception concerns disclosures to or requests by a healthcare provider for treatment; internal uses and payment or operations activities remain subject to their applicable rules.

A paid or incentivized referral source may also be an endorser under the FTC Endorsement Guides when consumers would understand its message as reflecting its views or experience. The Guides are administrative interpretations of Section 5. They state that endorsements must be honest, cannot convey a deceptive claim the advertiser could not make directly, and must clearly and conspicuously disclose unexpected material connections. Disclosure does not cure a ranking whose position is determined by payment. Substantiate access, clinical, outcome, and payer claims before publication. BACB Standards 5.07 through 5.09 separately set rules for covered behavior analysts' solicitation and use of client or stakeholder testimonials.

Use approved, purpose-specific channels. A referral dashboard rarely needs clinical details. If it contains PHI, apply the permitted pathway, role-based access, and applicable minimum-necessary rules. Aggregation alone does not establish HIPAA de-identification. HHS de-identification guidance identifies two methods: Expert Determination and Safe Harbor. Use one before treating dashboard data as de-identified. Keep marketing attribution separate from clinical decision making.

A fictional monthly cohort

At a July 10 reporting cutoff, a fictional practice includes 30 unique, non-test inquiries received from June 1 through June 30. Duplicates were removed before cohort freeze, every two-business-day contact window has elapsed, and no other record is excluded. The clock begins at recorded inquiry receipt and counts the practice's documented business days. Recorded sources are 12 pediatricians, 10 self-directed inquiries, and 8 schools. Twenty-four have a documented first outreach attempt within the target: 24 of 30.

By the cutoff, 18 have completed the predeclared intake-fit review: 18 of 30. Six remain open and six closed before review. Because the denominator is all June inquiries, label this “review completion among June inquiries,” not “completion among review-eligible inquiries.” Among the 18 reviewed inquiries, mutually exclusive first dispositions are onboarding for nine, waitlist by choice for five, and information about other providers for four: 9 of 18, 5 of 18, and 4 of 18.

A source-stage rate uses that source's eligible denominator for the same window and stage. If six of 12 pediatrician-attributed inquiries complete review, report 6 of 12, not 6 of 30. Predeclare the capture method, duplicate rule, unknown-source handling, cutoff, exclusions, and correction rule. Report raw counts, and do not rank small sources on raw conversion without considering case mix, payer or network constraints, geography, access needs, capacity, and wait time.

Track first-outreach timeliness, review completion, stated access needs, wait time, source-data accuracy, complaints, relationship disclosures, authorization outcomes, and source corrections. These measures describe workflow and association. They do not establish that a source caused acceptance, care outcomes, or payment.