Ahh.. Ok. OUCH. .. I say ouch if there is a financial relationship between your clients (providers) and your facility, yes indeed you have some stark issues.. EVEN if your not billing insurance companies.. Depending on the "arrangement" you might want to have your boss/client check with his/her attorney. Here's problem I see. IF there is NO financial link between the lab/provider.. well then how are you getting paid? By violation of stark the lab shouldn't get more than the services are worth, so hopefully the financial relationship does not go beyond that. IF the provider is NOT being compensated by the provider.. the obvious next question would be, then who's paying them? Can't be working for free. As the biller it's good to see your asking this because it could be a problem for you as well since you do the billing.