Savings Hub Participation Addendum

(For Pharmacies & Healthcare Sites)

Effective date: December 1, 2025

This Addendum supplements and is incorporated into the StrategiesRx Terms of Use. This Savings Hub Participation Addendum (“Addendum”) applies to pharmacies, clinics, and healthcare sites (“Participant”) that enroll in the StrategiesRx Savings Hub program (the “Program”). By participating in the Program, you agree to the Terms of Use and this Addendum. In any conflict, this Addendum controls for matters specifically relating to Savings Hub participation.

1. Purpose of the Program

The Program is designed to help pharmacies and healthcare sites integrate the StrategiesRx platform into patient-facing workflows to educate patients about potential, lawful cost-saving pathways for prescription medications. The Program is an educational and operational support model, not a referral program, incentive program, or marketing arrangement.

2. No Referrals; No Inducements

The Program does not provide or exchange referrals. No remuneration is offered or provided in return for the referral of patients, prescribers, or federally reimbursable items or services.

The Program must not be used to:

  • induce patients to patronize the Participant’s pharmacy,
  • influence a prescriber’s choice of pharmacy, or
  • generate federally reimbursable business.

The Participant is solely responsible for ensuring that all arrangements comply with the federal Anti-Kickback Statute, the Civil Monetary Penalties Law (beneficiary-inducement rules), and state fraud-and-abuse laws.

3. Branding and Public Representations

Participants may describe themselves as a “StrategiesRx Savings Hub” only as permitted by this Addendum.

Participants may not:

  • imply partnership, ownership, endorsement, or joint control with StrategiesRx;
  • state or suggest that StrategiesRx guarantees savings, coverage, approval, or reimbursement;
  • use the StrategiesRx name or logos in a manner inconsistent with brand guidelines provided separately.

All public-facing descriptions must be factual, educational, and consistent with CMS and state pharmacy board advertising rules.

4. Marketing and Communications Restrictions

Participant agrees not to:

  • use the Program for plan-specific marketing or Medicare Advantage / Part D steering;
  • use the Program in any communications governed by CMS marketing rules without independently ensuring compliance;
  • advertise or suggest that manufacturer assistance, coupons, or PAPs are available for federal program beneficiaries.

All patient communications must be educational and may not guarantee savings or imply eligibility for any specific third-party program.

5. Patient Privacy and Data Handling

The Program and platform are designed to operate without PHI.

Participant must not enter PHI into the platform unless a separate Business Associate Agreement (BAA) is executed.

Participant is solely responsible for:

  • its own HIPAA compliance,
  • secure handling of any patient information used outside the platform, and
  • compliance with state privacy laws.

6. Responsibilities of the Participant

Participant agrees to:

  • train staff on proper use of the StrategiesRx platform;
  • avoid representing the Program as a billing, insurance, or clinical decision-support tool;
  • verify all manufacturer or foundation criteria before communicating options to patients;
  • ensure signage and printed materials follow StrategiesRx brand guidance.

7. Fees

Program fees are for access to the platform’s tools, educational resources, and branded materials. No fees are conditioned on or vary with the volume or value of referrals or federally reimbursable business.

Participants may choose to offer their own “Savings Checkup” or “Medication Affordability Review” fees to consumers, at their sole discretion. Any such fees must comply with applicable law, including prohibitions on inducements.

8. Independent Contractor Status

Nothing in this Addendum creates a partnership, joint venture, agency relationship, or financial arrangement between Participant and StrategiesRx. Each party acts independently.

9. Termination

StrategiesRx may revoke Savings Hub status if Participant violates this Addendum, misrepresents the Program, or engages in unlawful or non-compliant practices.

Upon termination, Participant must discontinue all Savings Hub branding immediately.

10. Survival

Sections regarding compliance, privacy, branding, indemnification, and legal obligations survive termination.

11. Contact

Questions about this Addendum may be directed to: Norma@Strategies4RXSavings.com.