Advantus Health Partners will operate with high ethical and regulatory standards as a purchasing agent for its members. In consideration of the administrative, contracting, and other services Advantus Health Partners performs in connection with purchases of vendors’ products and services by members through Advantus Health Partners’ contracts with vendors, vendors often pay Advantus Health Partners an administrative fee. Advantus Health Partners distributes to its members all or portions of these administrative fees, based on amounts which exceed Advantus Health Partners operating costs to provide GPO services. Advantus Health Partners calculates each member’s spending and purchasing volume under the vendors’ contracts for purposes of allocating such administrative fees. In order to permit members to comply with requirements of the Federal antikickback statute discount safe harbor, Advantus Health Partners provides periodic reports to its members of all allocated administrative fees and portions of such administrative fees distributed to each member.  Advantus Health Partners informs all vendors that they may have reporting requirements related to any administrative fees that do not qualify as bona fide service fees (such as the requirements imposed on pharmaceutical manufacturers with respect to price reporting) that administrative fees may be passed through to its members as rebates, which enables vendors to comply with their own price reporting requirements.