If you are a billing company you need to stay away and out of all marketing related services as it's considered illegal under anti-kickback statutes and fee splitting regulations.. anything that brings patient's into the practice has to remain OUT of your hands and separate. On the issue of advising them, i always tell them to consult their attorney, I don't think they can do such an offer unless they fully outline the disclosure because they can't do it for Medicare, Medicaid, and any contract managed care plans.