The Covenant · Reddenda's business model, published in full· our business model, in full

The rate index that will never take a dollar from a health plan.

The standing covenant. Practiced from day one: no payer money, ever.

Free forever. We get paid after your check gets bigger. Every factual claim we make on this page about another company, a federal rule, or a court docket is cited at the bottom. Everything about our own economics is labeled modeled.

01

Close the exit with a charter.

Four covenants, going into the certificate of incorporation, that a company funded by health plans could never sign.

02

Open the door with a statute.

Federal arbitration bars the arbitrator from billed charges, from usual and customary rates, and from every public-payor rate. On price, what is left is the evidence class our index is built from.

Status, stated plainly: these terms are in force as we operate today; the formal certificate is being prepared for filing with counsel. Every projection on this page is modeled, not guaranteed, and is labeled as such where it appears. Where a tool is already live, we mark it live. Where it is not, we say so. We will publish the filed instrument here, in full, the day it exists.

Schedule a discovery call Read the whole thing

01 · The provocation

The insurers just got armed. Nobody is arming the provider.

Six months of public record. We are not telling you anything they did not announce themselves.

  1. January 12, 2026

    Zelis acquired Rivet.

    Rivet is a provider-side revenue cycle analytics company. Its tools help practices detect payer variances, model payer contracts, and recover underpaid claims. Zelis, in its own announcement, called Rivet a leader in revenue cycle analytics. Zelis says it serves more than 750 payers, including the top 5 national health plans, regional health plans, TPAs.

    Source 1: Zelis press release, “Zelis Acquires Rivet”

  2. March 30, 2026

    A federal judge let the providers' antitrust case proceed.

    Providers allege that Zelis and five major insurers conspired to suppress out-of-network reimbursement. Judge Brian E. Murphy of the U.S. District Court for the District of Massachusetts held those allegations plausible enough to proceed. The order reads: Defendants' motion to dismiss, Dkt. 96, is DENIED. The defendants are Zelis and Aetna, The Cigna Group, Elevance, Humana, and UnitedHealth Group. The claim is brought under Section 1 of the Sherman Act.

    Zelis denies the allegations. No court has ruled on the merits. Zelis filed its answer to the consolidated class action complaint on June 8, 2026.

    Source 4: In re Zelis Repricing Antitrust Litig., No. 1:25-cv-10734-BEM (D. Mass.)

  3. June 24, 2026

    Zelis launched an AI product for the other side of the table.

    Zelis NSA Claim Advantage, which Zelis describes as an AI-native solution to help payers manage No Surprises Act Independent Dispute Resolution. On its product page, Zelis tells payers the product will reduce avoidable IDR exposure, maximize win rates and defend reimbursement decisions, and Reduce disputes, improve win rates and protect margins.

    Source 2: Zelis launch release · Source 3: Zelis NSA product page (for the quoted product copy)

  4. In the same release

    The number they market to payers.

    The solution builds on Zelis' proven NSA performance, including processing $2.39 billion in NSA claim savings in 2025 with only approximately 8% of claims escalated to IDR.

    Zelis press release, June 24, 2026

    Read the direction of the money. Every dollar of that is a dollar a payer did not pay out on an out-of-network claim. And in the providers' antitrust complaint, as summarized by the court: Zelis then receives a percentage of the difference between the amount an OON provider charges, and the amount actually paid. That is an allegation recited by the court, accepted as true only for the purpose of the motion. Zelis denies the allegations.

    Source 2 · Source 4, Dkt. 185 at 4

So the provider side of the table now faces an AI product built to beat it, sold to more than 750 payers, by a company that also owns a provider-side analytics tool. Others sell rate data to providers. None of them can promise a payer will never be their customer, and the one provider-side tool that could have answered this now belongs to the company selling the weapon. Nobody is building an index a payer cannot buy.

That absence is the company.

02 · The wedge

There is a room where the payer's favorite benchmarks are barred by rule.

The No Surprises Act created a federal arbitration. 45 CFR 149.510(c)(4) tells the certified IDR entity exactly what it must weigh, and exactly what it may not touch.

Must consider

  • The plan's qualifying payment amount (the QPA) for the same or similar item or service.

Must then consider, on the evidence a party submits

  • The market share held by the provider or facility, or by the plan or issuer, in the geographic region.
  • The contracted rates between that provider and that plan during the previous 4 plan years.
  • Training, experience and quality measures. Patient acuity and complexity. Facility teaching status, case mix and scope of services.

Must not consider

  • Usual and customary charges.
  • The provider's billed charges.
  • Any public-payor rate. Medicare. Medicare Advantage. Medicaid. CHIP. TRICARE.

Stated precisely, because precision is the product: the arbitrator may weigh more than price. Training, acuity and case mix are all admissible. What is closed is the rate question. Every other rate benchmark is off the table. On price the arbitrator is left with the QPA and the commercial contracted rates between that provider and that plan, read against local market share. That is the evidence class our index is built from. This is the rare reader who is required to weigh what a party puts in front of him, and who is barred by rule from reaching for the benchmarks the payer would rather use.

0.0M+

Disputes initiated from April 2022 through the end of 2024.

CRS R48851

0

Disputes initiated in the first half of 2025 alone, up 39 percent over the prior six months.

CMS Federal IDR Public Use Files, 2025 Q1 to Q2

0%

Of cases that reached a payment determination in H1 2025, the arbitrator selected the provider's offer. Up from 85 percent in 2024.

CMS PUF, 2025 Q1 to Q2

0%

Of award amounts in H1 2025 exceeded the payer's own qualifying payment amount.

CMS PUF, reported by the American College of Radiology

Scope, honestly: 88 percent is the share of payment determinations, not the share of disputes filed. About 20 percent of disputes submitted in H1 2025 were ineligible for IDR.

And the regulator just opened the door

$115$15

On June 11, 2026 the federal fee to initiate an IDR dispute dropped from $115 to $15 per party, a cut of roughly 87 percent, under the CMS Federal IDR Operations Final Rule. It is in effect today.

CMS Federal IDR Operations Final Rule

Who pays the arbitrator

$200 to $840

The certified IDR entity's fee for a single determination. $268 to $1,173 batched. It is paid by the party that loses. Filing costs $15. Winning is the entire economic question, and the exhibit is aimed at deciding which party loses.

CMS, Certified IDR Entity Fee Update, December 2025

03 · The instrument

Four covenants. Going into the charter, not into the marketing.

We are converting to a Delaware public benefit corporation. DGCL 365(a) puts an affirmative statutory duty on a PBC board to balance stockholder returns against the specific public benefit that corporation names in its certificate. Ours will name one: conflict-free, provider-side rate transparency. But what actually closes the exit is not the status. It is the covenants. Open any one of them to read the draft language.

I

No adverse money.

Never any revenue from, or control by, a Prohibited Party. The test is objective and auditable: any entity deriving more than 10 percent of trailing-four-quarter consolidated revenue, per its own audited financials, from health-plan or insurer operations, TPA and ASO services, PBM services, or repricing.

It kills: the funder conflict.

II

No adverse use.

No score, artifact, feed, API or export may ever be sold, licensed or furnished to any party for the purpose of paying a provider less, screening or valuing a non-consenting provider, or making any credit, employment, insurance or housing decision about a natural person. The index cannot be used against its subject.

It kills: the FCRA exposure, the buy-side acquirer conflict, and the plan-sponsor conflict, in one clause.

III

No recommended price.

We never compute, recommend or publish a target price, a recommended ask, or a coordinated timing signal. Not for anyone, not ever. No forum, no polling, no coordination. We publish observed, historical, aggregated positions, built only from data the federal government already requires payers to disclose. We facilitate no agreement among providers and we coerce no one.

It kills: the coordination question, at the root.

IV

No collections.

We will never refer a provider to collections, never sue a provider for a fee, and never report one to a credit bureau. Ever. If an invoice is disputed, there is a one-click void button and the invoice is gone.

It kills: the thing we refuse to become.

Status: drafting. Not yet filed. We are also structuring the amendment power so that it cannot be exercised by a buyer alone. Counsel is selecting the instrument. We will publish the filed certificate here, in full, and every word of it will be readable before you ever give us a dollar.

Stated against our own interest: public benefit corporation status alone gives a provider no enforceable right. DGCL 365(b) says a PBC director has no duty to any person on account of that person's interest in the public benefit, and DGCL 367 limits standing to enforce the balancing duty to stockholders holding at least 2 percent of shares. That is exactly why the protection has to live in the covenants and in the contract, not in the label. We will publish which instrument counsel selects. We would rather you read this from us than find it yourself.

04 · Why it cannot be copied

Their scale is their disqualification.

A competitor with health-plan revenue can never sign covenant I. Not because it is expensive. Because it is a sentence about their past, and the past is finished.

The appraisal rule

Federal banking regulators do not let a lender rely on an appraisal the borrower ordered. The rule sits in the appraisal regulations and the Interagency Appraisal and Evaluation Guidelines that implement FIRREA Title XI: an institution's use of a borrower-ordered or borrower-provided appraisal violates those regulations, because independence is compromised the moment the interested party picks the appraiser.

A rate index funded by the payer is the same defect, wearing a different suit.

The underwriters' laboratory

Underwriters Laboratories was organized in 1894 with backing from the fire insurance underwriters: the party who ate the loss when a certification was wrong. The certifier was funded by the side with something to lose from a false pass.

In rate intelligence, the party with something to lose from a false benchmark is the provider. So the provider is the only party who can fund it. That is the whole design.

The Signatory Register

In build. Not yet shipped.

We are publishing a public register of who owns whom and who pays whom in rate intelligence: entity, owner, disclosed fee model, payer relationships, active litigation with docket number. Primary sources only. No grades. No unsourced adjectives. And one more column:

EntityDisclosed fee modelPayer relationshipsInvited to sign the CovenantResponse
Reddenda Flat fee per artifact. Flat fee once, after a documented rate increase lands. Channel partner commission: a percentage of the fee we collect, paid to the referring partner, never added to what the practice pays. The rate is published in this row the day the first partner agreement is signed. Any other engagement is scoped on a call. None. Covenant I will forbid them. Author Author. Signs on filing.
Every other company in rate intelligence To be published as disclosed To be published from primary sources Invitations going out Awaiting response

The Signatory Register, day one. We fill in the only row we can fill in honestly, and we will publish every answer exactly as it arrives.

This register is empty on purpose. It is the honest empty state, and it fills itself. A refusal to sign a document titled I take no money from health plans, printed in front of a provider audience, is an answer.

05 · What is free, forever, unmetered

Most of the product costs nothing, and always will.

No account. No card. No meter. We will never meter the habit: a user who is scared to ask a question does not share what she found, and the share is the growth model.

Read this before you read the prices. This is the free layer under the Covenant, and the Covenant is in drafting. Every card below is stamped with what it is today: Live today or In build. Not yet shipped. Reddenda's live, current pricing is on the pricing page, and where it differs from the Covenant model we say so on the card.

The fear killer

In build. Not yet shipped.

The Leverage Map

The single biggest reason a practice never negotiates is not a missing benchmark. It is the fear of being dropped. Nobody has ever shown a doctor their own leverage.

Federal law requires a Medicare Advantage plan to do two separate things: meet maximum time and distance standards, and contract with a minimum number of each provider specialty type. CMS sets and publishes both numbers every year in its Health Service Delivery Reference File, and both vary by county type. We will compute your position against CMS's own published file.

CMS requires this Medicare Advantage plan to contract with a minimum number of orthopedic surgeons for this county, and to keep 90 percent of its members within 20 minutes of one. Based on the payer's own published in-network file, we count five orthopedic surgeons in network here. You are one of them.

Illustrative sentence, not a live output. The built page will compute every number per county, from the published file. Never hardcoded.

Honest limits, stated in place: this is CMS's published minimum for the plan, not a guarantee about your contract, and CMS grants exceptions where providers are genuinely unavailable. There is no federal network adequacy standard for self-funded employer plans, which ERISA shields from state insurance regulation. For fully-insured commercial plans, the standards are set state by state. Parallel federal standards exist for Medicaid managed care (42 CFR 438.68, numbers set by each state) and for Exchange plans (45 CFR 156.230, numbers set in the Exchange's annual guidance). And one more, which matters: the network CMS actually evaluates lives in the plan's Health Service Delivery tables, which are not public. Our count is derived from the payer's published machine-readable file, which is a different artifact. We will show you which one we used. The Leverage Map is strongest where a federal standard exists. Source 9

$0 forever, on launch. No account.

In build. Not yet shipped.

The Consequence Model

The other half of the answer to fear. Not a reassurance, a number: If this payer terminated you tomorrow, they are 14 percent of your contracted revenue, and there are 41 in-network practices in your specialty within 10 miles. She sees the real downside instead of imagining a worse one.

Illustrative sentence, not a live output. The real figures will be computed per NPI from published files.

$0 forever, on launch. No account.

Live today

The Demand Index

Payer by CPT by metro rate pages. What every payer has agreed to pay, for every procedure, in every market we have indexed. Every number linked back to the payer's own federally mandated machine-readable file, and an honest empty state where we do not hold the data yet.

$0 forever. No account. Open it →

Live today

The Identity Index and the RateScore

A page for every NPI in America. The RateScore is a 300 to 850 position against the local peer median and the provider's own payers. Local peers only. We never benchmark a provider against a countrywide average, because a rate in Fresno is not a rate in Manhattan. Published with the record count and the confidence band, so you can see when we do not know.

$0 forever. No account. Open it →

In build. Not yet shipped.

Your own NPI

Possession-verified: a code sent to the NPPES-listed phone or practice address, an email at the practice domain, or a state license lookup. Never a typed field. Then unlimited depth, unlimited watched contracts, unlimited 120-day renewal countdowns, a monthly re-score, and free unlimited correction of your own record.

In 2022 the FTC ordered Dun & Bradstreet to change its practices after finding it deceived businesses trying to correct inaccuracies in their own credit reports and failed to update errors on those reports. In September 2025 D&B agreed to pay $5.7 million to resolve alleged violations of that order. Correcting your own record on Reddenda will be free, unlimited, and always will be. Source 10

$0 forever, on launch. Verification required.

Free under the Covenant. Not yet live.

The Leverage Memo

The signable, payer-ready counteroffer. Every number cited to the payer's own published file. It states a position, a distribution, and your own rate history. It never states a target, a demand, or a recommended ask. That is covenant III, and it is how we build the memo today, filed or not.

The honest version, because a price is a fact: the Leverage Memo is a paid product today. It is $299 one-time on the pricing page. Free and unlimited is the Covenant model, and it goes live when the free layer does. We will not print a $0 next to something we currently charge for.

Today: $299. Under the Covenant: $0, unlimited.

Live today

Verification, for the reader who did not pay

Every artifact carries a free, permanent, no-account verification URL. The payer's analyst opens it. The arbitrator opens it. The party who does not pay is the party who enforces the transaction. That is the whole trick, and it only works if verification is free.

$0 forever. No account. See it →

06 · How we get paid

Two ways. Both of them after the value lands.

The Exhibit is live at $149. The Practice fee is the Covenant model: it is not purchasable today, and it is scoped on a call.

Lane one Live today

The Exhibit

$149per filed IDR exhibit

Wholesale for certified firms, billing companies and RCM partners is scoped on a call. It is never quoted inline.

  • It carries what the QPA structurally cannot. The QPA is the payer's own median of its own contracted rates, and 45 CFR 149.510(c)(4)(iii)(E) tells the arbitrator not to re-weigh information already accounted for by it. So the exhibit is built to carry the things the QPA does not contain: the market share held by the provider and by the plan in that region, the contracted rates between that provider and that plan over the previous four plan years, and the local distribution across payers rather than inside one.
  • Zero PHI, architecturally. No patient. No chart. No diagnosis. No date of service. It is a market evidence document, not a claim document. There is no BAA because there is nothing to cover. No PHI required, which is not a claim of HIPAA certification.
  • A flat fee that never varies with the provider's collections. It is not a division of professional fees under any state's doctrine, and it never turns on patients, tests, or referrals.
  • Filing costs $15. The certified IDR entity's fee, $200 to $840 for a single determination, is paid by the party that loses. Winning is the entire economic question, and $149 is the only line on that invoice aimed at deciding which party loses.

The compelled reader

An arbitrator is not a marketing audience. He is required to weigh the credible evidence a party puts in front of him, and he is barred by rule from reaching for the benchmarks the payer would rather use. He is the rarest reader in American healthcare, and he is reading on a deadline.

Lane two Covenant model. Not yet purchasable.

The Practice, after the bigger check clears

Flat feeonce, after the bigger check clears

Scoped on a call. Multi-NPI and portfolio pricing is never quoted inline.

  • We do not depend on the payer's published file, because a payer can route a concession off-schedule. We bill when any one of three things happens. Step through them.

The file. The new rate appears in the payer's own published machine-readable file. Public, dated, and checkable by anyone, including you.

If money moves, it moves through paper or it moves through the check. There is no third door.

  • We bill on the check, not on the file. The invoice is due after the first bigger payment actually lands.
  • The double gate. A memo must have been minted and affirmatively marked sent, and timestamped before the rate moved.
  • The void button. One click, labeled “this wasn't us,” and the invoice is gone. No argument.
  • No collections. Ever. That is covenant IV, and it is our policy today, filed or not.

Reddenda identifies documented reimbursement opportunity from public contracted rates and submitted practice inputs. Actual outcome depends on payer response, contract terms, documentation, and negotiation. Nothing here is a promise of recovery, and no dollar figure on this page is a guarantee.

Schedule a discovery call

There is no checkout on this page. Multi-NPI and portfolio engagements are always a conversation.

07 · The economics

The margin, and the honest hole in it.

Modeled, not guaranteed

95 to 99%

Modeled gross margin. A precomputed RateScore lookup is one indexed row read.

~$0.16

Modeled inference cost of one Leverage Memo, written by Opus over deterministic numbers. The numbers are never generated by a model. The language layer is.

$2 to $7

Modeled total AI cost per month at 5,000 providers. The payment processor costs more than the intelligence does.

HorizonModeled net revenueModeled ending base of verified, claimed NPIs
Year 1$4.7M35,000
Year 2$29.5M200,000
Year 3$71.7M550,000

Revenue model. MODELED, NOT GUARANTEED. These are external benchmarks applied to the asset, not measured results.

The number we will not hide from you

Reddenda has zero measured self-serve conversion today. Early signups exist; conversions do not yet, and the sample is far too small to mean anything. That is uninformative, not damning: it does not establish that the model works, and it does not rule it out either. The dated, exact figures live in the data room, not on a marketing page.

Every projection above is a model, and we have told you it is a model everywhere it appears. The pricing is published, the checkout is live, and the certificate is being prepared for filing with counsel. If you are diligencing this business, that paragraph is the one we would want you to read first, and it is the reason we wrote it before you asked.

08 · Who this is for

Specialty-agnostic. National. Six surfaces.

The wedge is the SMB provider layer the incumbents ignore, because they sell up-market at six figures an engagement.

  • 01

    Independent and SMB practices

    The layer the incumbents ignore. One NPI, one payer, one renewal, and nobody in the building whose job is the rate.

  • 02

    Billing companies and RCM firms

    Portfolio rate intelligence across every client NPI. The wholesale exhibit lane is built for you, and it is scoped on a call.

  • 03

    DME suppliers

    Same statute, same index, same evidence class. Rates and market structure do not care what the item is.

  • 04

    Specialty groups

    Ortho, GI, OB/GYN, PT and every other specialty. The index is built the same way for all of them, and the peer set is always local.

  • 05

    MSOs and multi-location groups

    Multi-NPI roll-ups are never gated and never priced inline. Every NPI, every payer, one board-ready view. Schedule a call.

  • 06

    Channel partners

    White-label and referral. Our commission is disclosed in our own row of the Signatory Register, at the top of the table, before anyone else's.

Nobody is arming the provider.

That is the whole opportunity, and it is written on the public record by the people on the other side of the table. If you are a practice, a billing company, an MSO, a channel partner, or an investor, the next step is the same one: a call.

Schedule a discovery call

There is no checkout on this page. Multi-NPI and portfolio engagements are always a conversation.

Appendix

Every citation on this page.

If a number is not here, it is labeled modeled. If a claim is not here, we cut it.

  1. 1
    Zelis press release, “Zelis Acquires Rivet,” January 12, 2026. Businesswire release 20260112989226. Zelis describes Rivet as “a leader in revenue cycle analytics.” Zelis company boilerplate: “more than 750 payers, including the top 5 national health plans, regional health plans, TPAs.”
    zelis.com/news/zelis-acquires-rivet
  2. 2
    Zelis press release, “Zelis Launches AI-Native Solution to Help Payers Address Rising IDR Challenges,” June 24, 2026. Businesswire 20260624077176. Product: Zelis NSA Claim Advantage. Source of the quoted sentence, “The solution builds on Zelis' proven NSA performance, including processing $2.39 billion in NSA claim savings in 2025 with only approximately 8% of claims escalated to IDR.”
    zelis.com/news/zelis-launches-ai-native-solution
  3. 3
    Zelis No Surprises Act product page. Source of the quoted product copy, “reduce avoidable IDR exposure, maximize win rates and defend reimbursement decisions,” and “Transform No Surprises Act (NSA) outcomes. Reduce disputes, improve win rates and protect margins.” This quote is from the product page, not the press release.
    zelis.com/solutions/out-of-network-solutions/no-surprises-act
  4. 4
    In re: Zelis Repricing Antitrust Litigation, No. 1:25-cv-10734-BEM (D. Mass.). Dkt. 185 (March 30, 2026) (Murphy, J.), Memorandum and Order on Defendants' Motion to Dismiss: “Defendants' motion to dismiss, Dkt. 96, is DENIED.” Dkt. 185 at 4 recites the plaintiffs' allegation, accepted as true only for purposes of the motion: “Zelis then receives a percentage of the difference between the amount an OON provider charges, and the amount actually paid.” Dkt. 234 (June 8, 2026), Zelis's answer to the amended and consolidated class action complaint. Consolidated with 25-11092, 25-11167, 25-11537. Zelis denies the allegations. No court has ruled on the merits.
    govinfo.gov: United States Courts Opinions, D. Mass. 1:25-cv-10734
  5. 5
    CMS Federal IDR Public Use Files, 2025 Q1 to Q2 (released January 21, 2026). 1,186,812 disputes initiated January 1 to June 30, 2025, against 853,374 in the prior six months. Provider's offer selected in 88 percent of payment determinations, against 85 percent in 2024. 87 percent of award amounts exceeded the qualifying payment amount, as reported by the American College of Radiology. About 20 percent of disputes submitted in H1 2025 were ineligible for IDR.
    cms.gov: No Surprises Act reports and public use files
  6. 6
    Congressional Research Service, R48851 (February 10, 2026). “From when the IDR process became operational on April 15, 2022, through 2024, over 2.3 million disputes were initiated.” Also: each participant pays a flat fee to participate, and the non-prevailing party pays the IDR entity's fee.
    congress.gov/crs-product/R48851
  7. 7
    CMS Federal IDR Operations Final Rule (issued May 28, 2026; published in the Federal Register June 4, 2026). Administrative fee of $15 per party per dispute, down from $115, for disputes initiated on or after June 11, 2026.
    federalregister.gov: CMS rules
  8. 8
    CMS, Certified IDR Entity Fee Update (December 29, 2025). Certified IDR entity fee ranges of $200 to $840 for single determinations and $268 to $1,173 for batched determinations. Individual certified IDR entities set their own fee within those ranges.
    cms.gov: No Surprises Act
  9. 9
    42 CFR 422.116 (Medicare Advantage network adequacy). An MA plan must meet maximum time and distance standards and contract with a specified minimum number of each provider and facility specialty type; the criteria vary by county type; CMS annually publishes the standards in its Health Service Delivery Reference File. The time and distance test requires access for at least 90 percent of beneficiaries in large metro and metro counties, 85 percent elsewhere, and CMS operates an exceptions process. Parallel standards: 42 CFR 438.68 (Medicaid managed care; states develop and enforce the quantitative standards) and 45 CFR 156.230 (Exchange QHPs; time and distance and appointment wait time standards set in the Exchange's annual guidance).
    ecfr.gov/current/title-42/section-422.116 · 438.68 · 156.230
  10. 10
    Federal Trade Commission, Dun & Bradstreet. April 2022: final order against D&B for deceiving businesses and failing to update errors on business credit reports. September 2025: D&B agreed to pay $5.7 million to resolve alleged violations of that order.
    ftc.gov: Dun & Bradstreet agrees to pay $5.7 million
  11. 11
    45 CFR 149.510(c)(4) (federal IDR payment determination). The certified IDR entity must consider the qualifying payment amount, and must then consider information a party submits relating to additional circumstances, including the market share held by the provider or facility or by the plan or issuer in the geographic region, and the contracted rates between that provider and that plan during the previous 4 plan years, alongside training and experience, patient acuity, and facility teaching status, case mix and scope of services. Under (c)(4)(iii)(E) it should not give weight to information already accounted for by the qualifying payment amount. It must not consider usual and customary charges, the provider's billed charges, or any public-payor rate including Medicare, Medicare Advantage, Medicaid, CHIP and TRICARE.
    ecfr.gov/current/title-45/section-149.510
  12. 12
    Delaware General Corporation Law 365 (public benefit corporation). 365(a): the board must manage the corporation in a manner that balances the pecuniary interests of the stockholders, the best interests of those materially affected by the corporation's conduct, and the specific public benefit identified in its certificate of incorporation. 365(b): a director does not, by reason of the public benefit, have a duty to any person on account of that person's interest in the public benefit. DGCL 367 limits standing to enforce the balancing duty to holders of at least 2 percent of outstanding shares.
    delcode.delaware.gov: DGCL subchapter XV
  13. 13
    FIRREA Title XI implementing regulations and the Interagency Appraisal and Evaluation Guidelines (December 2, 2010; agency FAQ 2018). An institution's use of a borrower-ordered or borrower-provided appraisal violates the agencies' appraisal regulations, because independence is compromised when the interested party selects the appraiser. Separately, on the Underwriters Laboratories analogy: UL was organized in 1894 with backing from the fire insurance underwriters, the party that bore the loss of a false certification. The UL comparison is an argument by analogy, not a legal claim.
    federalreserve.gov: Interagency Appraisal and Evaluation Guidelines (SR 10-16)