Generally speaking, the offering of internet coupons/vouchers, in situations in which the recipient of the coupon/voucher has initiated contact with the marketing organization and requested notification of deals, may be structured in a manner that does not constitute a prohibited fee-splitting or referral fee arrangement, as long as the negotiated fee between the internet coupon/voucher advertiser and licensee represents reasonable compensation for the cost of advertising, including a reasonable profit. However, because there are numerous possible variations in the types of advertising arrangements, each arrangement must be analyzed on its own facts in accordance with applicable statutory and regulatory provisions, including provisions relating to the exercise of undue influence on a patient or client, fee splitting, referral fees, and prohibitions against false and misleading advertising (Education Law section 6509-a and section 29.1[b][2], [3], [4], and [12] of the Rules of the Board of Regents).