07/18/2025    Zach T. Heard

Is This a Stark Law Violation? (George Cioe)

EBM Medical categorically rejects and forcefully
disputes the false and misleading assertions
recently made by the CEO of the Tetra Corporation
on this website. These statements irresponsibly
mischaracterize EBM Medical’s business model,
falsely suggest legal violations, and attempt to
undermine the ethical and lawful practices of
healthcare providers who serve patients using EBM
Medical’s innovative platform.

It is important to note that The Tetra Corporation
is not an objective, disinterested party, but
rather a direct, head-to-head competitor to EBM
Medical, which stands to gain from any
misinformation disseminated about our company.
This inherent conflict of interest fundamentally
undermines the credibility and integrity of these
statements. Tetra’s personal stake in harming a
leading competitor creates a clear and undeniable
motive to spread fear, uncertainty, and
misinformation in an effort to damage EBM
Medical’s reputation and mislead providers.

Based on our extensive, ongoing legal review, EBM
Medical’s business operations have been carefully
structured and continuously evaluated to ensure
full compliance with federal and state healthcare
laws, including the Stark Law, the Anti-Kickback
Statute, and all applicable professional and
ethical standards. The insinuations that EBM
Medical engages in “kickbacks,” “rebates,”
“reimbursements,” or “fee-splitting” are not only
entirely unfounded but also reflect a fundamental
misunderstanding—or a willful misrepresentation—of
the facts. For the past decade, EBM Medical has
worked closely with its legal counsel to undertake
frequent review of EBM’s business model to ensure
regulatory compliance.

In response to these unfounded and unprecedented
attacks, we are making available the comprehensive
legal analysis from our counsel to set the record
straight, dispel misinformation, and clearly
demonstrate that EBM Medical’s business model is
fully compliant and ethically sound. We strongly
encourage all medical professionals and industry
stakeholders to carefully examine these facts and
to consider the true nature and motivation behind
these misleading claims.

Zach T. Heard, Founder and Managing Partner, EBM
Medical, LLC

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