HARPWellness

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.