Three Rivers Provider Network DirectPay (TRPN) is at it again, this time faxing an unprompted and potentially dangerous Business Associate Agreement (BAA) to a California provider.

Labeling the fax a “HIPAA Compliance/Required Document,” TRPN purports to set forth terms for handling Protected Health Information (PHI). However, the “agreement” inexplicably includes discount reimbursement terms that have no place in a typical BAA for PHI handling or HIPAA compliance.

We strongly urge providers never to sign an unexpected document from TRPN, a company with a long history of shady practices and outright deceit.

Surprise “Required Document” From TRPN

In February of 2026, TRPN faxed the contract below to a daisyBill client, a California Medical-Legal services company. Wisely, the client decided to ignore the fax and to pass it along to daisyNews.

The document appears to be a standard BAA. However, a close inspection reveals that (in addition to being wholly unsolicited), the document is misprinted in several places, obscuring some of the terms.

Even if it were advisable to sign a document from TRPN (and it is not), a provider would be in the dark about exactly what they were agreeing to.

Bonkers Discount Payment Terms

Perhaps the strangest and most nefarious thing about the TRPN BAA is that it includes terms for discount reimbursement.

This is, to put it mildly, not standard for a BAA or HIPAA-related agreement.

Even worse, the specific payment terms are potentially incredibly harmful.

The document claims to dictate rates for “all covered services, including In-Network/Out-of-Network Auto/Workers’ Compensation without exception.” Stating "All claims shall be processed through this Agreement on an exclusive basis” and “Claims processed through any other non-exclusive Agreement shall accrue to TRPN DirectPay,” TRPN effectively asserts that every bill the provider submits is subject to the agreement.

As for the actual reimbursements, TRPN lists a string of nonsensical discount amounts, including various “percentiles” of Medicare or state fee schedule rates and “Percentage Off Billed Charges 35%.”

To be clear: BAAs do not include discount reimbursement terms, let alone terms as ill-defined and detrimental as these.

A BAA has a specific, defined purpose under HIPAA to govern how a vendor or partner handles PHI. For TRPN to couch absurd discount terms in a BAA looks very much like an attempt to fool a provider into signing what appears to be a standard document unrelated to reimbursement, only to become ensnared in a grisly contract.

TRPN’s Reputation Precedes It

This is not the first time TRPN has gone fishing for providers’ signatures on unsolicited agreements.

daisyNews published several articles about a scheme in which TRPN sent random checks to practices that, once deposited, supposedly executed an unwanted contract between the provider and TRPN.

The California Medical Association called TRPN’s activities “illegal” and “deceptive.” Nevada’s Insurance and Safety Fire Commissioner issued a cease-and-desist order for the check-mailing scheme. At one point, the IRS reportedly raided TRPN offices.

While this is the first we’ve heard of TRPN specifically sending out BAAs, the company has a longstanding habit of throwing scams at the wall and seeing if they stick. Providers have fought back against TRPN and prevailed, though the company’s nefarious efforts must have been at least occasionally successful.

Providers, take it from daisyNews: instruct your staff to treat any communications from TRPN as toxic.

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