13. Compliance
Compliance Posture
Investors reward this slide in healthcare; its absence is a red flag.
- Cash-pay only
- Cash-pay only on the wellness line. No PBM contracts. Removes the primary anti-kickback exposure.
- PC/MSO separation
- PC/MSO separation for all clinical services, with flat or fair-market-value management fees, never a percentage of patient revenue. Designed for Colorado's strict CPOM doctrine and the active 2024–2026 enforcement cycle.
- No referral compensation
- No compensation to any referral source tied to volume or value.
- Clinician pay
- Clinicians salaried, never commissioned on product.
- Product testing
- Third-party testing and published COAs on the private-label line. No proprietary blends.
- General-wellness positioning
- Maintained deliberately. A composite score driving specific recommendations can drift toward regulated clinical decision support; scoring language stays descriptive, reviewed by counsel pre-launch.
- Peptides
- A roadmap item with a dated catalyst, not a launch SKU. In July 2026 FDA's Pharmacy Compounding Advisory Committee recommended six of seven peptides (including BPC-157 and TB-500) for the 503A bulk substances list, overruling FDA's own scientists on close votes. These are recommendations only; formal rulemaking realistically runs into 2027, and nothing is legal to compound today that wasn't before.
Cash-pay removes federal anti-kickback exposure; it does not remove state law. The structure above is built to hold under scrutiny, not merely to launch quickly.