Compliance is a product feature, not an afterthought.

• Provide admin, technology, and support services under MSA
• Operate CarePath patient engagement (non-clinical only)
• Handle subscription billing and pharmacy coordination
• Maintain HIPAA compliance documentation
• Provide BAAs to all technology vendors
• Conduct state CPOM review before each market entry

• Practice medicine or make clinical recommendations
• Issue prescriptions or control prescribing
• Employ physicians in a clinical capacity
• Set clinical protocols or treatment pathways
• Process data requiring clinical licensure
• Operate as a telehealth platform

Healthcare Counsel

MSO/CPOM specialist engaged for TX, FL, GA before pilot launch. $25–40K initial engagement + $2K/month retainer covering all state expansions.

• CPOM analysis per state
• MSA review and drafting
• Ongoing regulatory monitoring

HIPAA Infrastructure

AWS HIPAA-eligible stack with BAA executed before any patient data touches the platform. Compliancy Group software active.

• S3, RDS, EC2, CloudWatch
• Secrets Manager
• BAA with all vendors

FTC Monitoring

GLP-1 telehealth has drawn FTC regulatory attention. Healthcare counsel monitors guidance and adjusts MSA terms and marketing copy accordingly.

• FTC guidance tracking
• Marketing copy review
• MSA term adjustments