Draft v0.1 · Document A8
Medical Disclaimer and Site-Wide Disclosures
The approved disclosure copy blocks: medical disclaimer, compounded-medication statement, prescription-required lines.
On this page (13 sections)
- Block 1. Site footer disclosure
- Block 2. Medical Disclaimer (page copy)
- Block 3. Educational content disclaimer (Learning Center and eBooks)
- Block 4. Compounded-medication statement (site level)
- Block 5. Prescription-required sentence and program variants
- Block 6. Results and testimonial disclaimer; Review and Testimonial Policy
- Block 7. About and Contact legal block
- Block 8. States We Serve (page template)
- Block 9. AI assistant disclosure (one line)
- Block 10. Privacy and cookie banner (one line)
- Block 11. Replacing the “HIPAA Compliant” badge and the “Licensed Providers in All 50 States” claims
- Block 12. How the care team works (one paragraph)
- Technical and drafting notes
Block 1. Site footer disclosure
Copy: full footer paragraph
Copy: short form (mobile footer, ad landing pages, email footers)
Optional lines for the pricing and checkout pages
- “WellPeps does not bill insurance, Medicare or Medicaid.” [VERIFY: HSA and FSA statement, requirement E3]
- “Labs are billed separately and are not part of your monthly price.”
Block 2. Medical Disclaimer (page copy)
Page copy begins. Page title: Medical Disclaimer
Effective date: [EFFECTIVE DATE] | Last updated: [LAST UPDATED] | Version [VERSION]
Page copy ends.
Block 3. Educational content disclaimer (Learning Center and eBooks)
Copy: article footer (short)
Copy: eBook front matter and last page (long)
Block 4. Compounded-medication statement (site level)
Copy: short form (product cards, ads, social)
Copy: standard form (program pages, quick view, footer link, checkout)
Long form
Link the standard form to the Compounded Medication Disclosure and Consent and, for weight loss, to the GLP-1 Medication Safety Information and Acknowledgment.
Block 5. Prescription-required sentence and program variants
Copy: standard sentence
Copy: very short (ad headlines, buttons’ small print)
Copy: wherever “free” appears
Copy: Weight Loss
Copy: Sexual Wellness
Copy: Hair
Copy: Healthy Aging and Vitality
Copy: Hormone Optimization (waitlist only)
Block 6. Results and testimonial disclaimer; Review and Testimonial Policy
Copy: results disclaimer
Copy: testimonial disclaimer (next to any review, story or quote)
Copy: Review and Testimonial Policy (public page)
Effective date: [EFFECTIVE DATE] | Last updated: [LAST UPDATED] | Version [VERSION]
Block 7. About and Contact legal block
Copy
Block 8. States We Serve (page template)
Copy: page introduction
Copy: footnotes under the table
Block 9. AI assistant disclosure (one line)
Block 10. Privacy and cookie banner (one line)
Copy: Variant A (use only while no non-essential tracker runs)
Copy: Variant B (use before PostHog, Curve or any ad pixel goes live)
Block 11. Replacing the “HIPAA Compliant” badge and the “Licensed Providers in All 50 States” claims
Requirement D21. Each existing claim below must be removed or substantiated before the site goes live. Locations come from a read-only search of wellpeps-site/src on 2026-10-01; run a full site search before publishing, because the same phrases recur.
Existing claim and where it appears | Why it must go or be substantiated | Replacement wording | Use the replacement only when |
|---|---|---|---|
“HIPAA Compliant” badge in the footer (Footer.astro). “HIPAA-compliant technology and systems” in FAQs and the assistant knowledge base (weight.ts, why-wellpeps.astro, knowledge.ts). | No HIPAA certification exists, so a badge reads as a seal it is not. “Compliant” is a legal conclusion. It depends on WellPeps’ HIPAA role (item H1, undecided), signed business associate agreements (none in hand), a risk analysis and a security program (item H5, not done). The marketing site holds no PHI. An unsupported privacy claim is a deception risk under FTC Act section 5 and a LegitScript Standard 6 problem. | Badge: replace the shield with a lock icon and the text “We protect your information,” linking to the Privacy Policy. FAQ now: “We take your privacy seriously. Read the Privacy Policy and the Notice of Privacy Practices to see how your information is handled.” FAQ later: “Health information you share with your clinician is protected by federal privacy law (HIPAA). Read the Notice of Privacy Practices.” | Now: counsel approves the first two. Later wording: after the H1 decision, signed business associate agreements and a published Notice of Privacy Practices. |
“Licensed Providers in All 50 States,” “50 States · Nationwide Care,” “50-State Licensed Provider Network” (Footer.astro; config.ts coverage string; content.ts; knowledge.ts; weight.ts; why-wellpeps.astro). The Terms page already flags it. | The licensure record (Schedule B) is not in hand, and the the agreement with the Practice warrants licensure only in “applicable states” (section 9(b)). Pharmacies must also be licensed per state, and some states restrict compounded GLP-1 (OH and CT positions; the California oral-form exclusion). LegitScript Standards 1 and 5 compare the claim to the licensure record (items LS1-PROVIDER-LICENSURE-SUBSTANTIATED and LS5-STATES-MATCH-LICENSURE). Publishing a shorter list on the States We Serve page while the footer says all 50 is the worst outcome. | Footer: “Licensed clinicians in the states we serve. See States We Serve.” Until the table is verified: “Care is available in select states. See where we serve.” FAQ “What states do you serve?”: “We serve [STATES SERVED]. See the States We Serve page for the current list. Availability of each medication varies by state.” | The States We Serve table matches the licensure record and the pharmacy dispensing matrix, and [STATES SERVED] is filled. |
“Compounded in FDA-registered U.S. facilities” / “prepared by FDA-registered U.S. compounding pharmacies” (weight.ts lead and body; knowledge.ts; hair.ts FAQ). | Patient-specific (503A) pharmacies are regulated mainly by state boards of pharmacy. “FDA-registered” describes outsourcing facilities and manufacturers, so the phrase misdescribes the pharmacies and can imply FDA oversight or approval of the product. FDA’s GLP-1 warning letters cite “FDA-approved pharmacy” and sameness claims. | “Prepared by state-licensed pharmacies.” | The pharmacy roster is confirmed and each pharmacy’s license is verified in the states it ships to. |
“Licensed U.S. pharmacy partners that meet applicable quality and regulatory standards” (knowledge.ts). | “Meet applicable quality standards” is an unsupported quality claim. | “State-licensed pharmacies.” | License evidence is on file. |
“Physician-guided care” (why-wellpeps.astro). | The clinicians’ credentials are unconfirmed (physicians, nurse practitioners or physician assistants). | “Licensed clinicians.” | The Practice confirms credentials; then “physician” may be used only where true. |
“Trusted. Certified. Committed to You.” (home trust bar, removed 2026-07-07; an internal document asks whether to restore it). | “Certified” implies a certification WellPeps does not hold until LegitScript issues one. The LegitScript badge is correctly hidden in the footer. | “Independent licensed clinicians. State-licensed pharmacies.” | Do not restore “Certified” until the certificate is issued and the use is licensed. |
“FSA/HSA” payment tile (Footer.astro). | Accepting an HSA or FSA card does not mean treatment is an eligible expense. Eligibility is set by the account administrator. | Remove the tile, or: “HSA and FSA cards can be used where your plan allows. Your plan administrator decides what is eligible.” | Requirement E3 (cash-pay acknowledgment) is settled. |
“Quest Diagnostics and Labcorp” named as lab partners (knowledge.ts). | Naming third-party brands implies a relationship. No lab partner terms are in hand (requirement B11). | “Low-cost lab testing through national lab partners when your clinician recommends it. Lab fees are billed separately.” | A lab agreement allows the names. |
A file named “Ozempic is Semaglutide.png” sits untracked in the repository root. | If it is meant for publication, it states or implies that a compounded product is the same as a brand drug. FDA’s letters target that message. | Do not publish. If a comparison is needed, counsel and the compliance review decide the wording (requirement J1). | Counsel and the compliance review approve it. |
Block 12. How the care team works (one paragraph)
Technical and drafting notes
Notes and rules for each part
From: Block 1. Site footer disclosure
Notes
- Replaces the current footer paragraph, which calls WellPeps “a platform that connects patients with licensed healthcare providers and pharmacy partners.” That description does not match the non-clinical brand role, and the paragraph lacks the prescription and compounded-medication statements the cheat sheet (section 9) requires.
- The copyright line currently says 2025.
- This is the cheat sheet’s Model B footer, adapted. It says “licensed clinician” rather than “licensed physician” until the Practice confirms credentials.
From: Block 3. Educational content disclaimer (Learning Center and eBooks)
Notes
- The Learning Center index already carries a one-line educational statement. Align its wording with the short form above.
- The “offers some of the treatments discussed” sentence is a material-connection disclosure and should stay.
- [REVIEWER LINE] is optional. Use it (for example “Reviewed by (name and credentials) on (date)”) only if a licensed clinician actually reviewed the piece. “Medically reviewed” that is not true is a claim problem.
- No dosing instructions or titration charts in educational content. A disclaimer under a dosing guide does not cure it.
From: Block 4. Compounded-medication statement (site level)
Rules
- Name a compounded product as compounded (for example “compounded semaglutide”). The oral weight-loss cards are still being renamed to “Compounded Oral ...”.
- Do not describe a compounded product by a brand name, as having “the same active ingredient as” a brand, or as “pharmaceutical grade.” Those are sameness or quality claims.
- The standard form is true only if the product status table (Open items) is accurate for every product shown on the page.
From: Block 5. Prescription-required sentence and program variants
Notes
- Medical director to confirm each variant against the product status table. The Healthy Aging variant assumes every product in that program is compounded; delete any that is not.
- LegitScript register item LS7-RX-REQUIRED-DISCLOSED: three of four programs currently lack an explicit prescription-required statement.
From: Block 6. Results and testimonial disclaimer; Review and Testimonial Policy
Notes
- Defaults chosen: no incentives, no outcome numbers, no before-and-after photos. Change them only with counsel and the compliance review (the wellpeps-compliance-review skill).
- Clause 2 supports requirement D19 and must be true of every form contract WellPeps uses; counsel to check the Patient Terms and Website Terms.
From: Block 7. About and Contact legal block
Notes
- The registered office is a registered agent’s address. Print it only as the registered office. It does not replace the business address (register item LS1-BUSINESS-ADDRESS-PUBLISHED).
- Optional line, once counsel agrees: “WellPeps, a Wyoming corporation, formerly Well PEPS Operations Corporation.” The contracts still carry the former name.
- The ownership sentence responds to LegitScript Standard 4 (register item LS4-PARTNER-ROSTER). Wording to be settled by counsel; it names no company.
- The email address, hours and any phone number must match what is actually monitored.
From: Block 8. States We Serve (page template)
How to complete the table
- Clinician availability: “Available” only if a licensed clinician of the Practice can treat patients located in that state. Otherwise “Not available.” Use “Limited” only with an explanation in Notes.
- Medication forms available: list the forms a patient in that state can receive (injection, oral, sublingual, topical), by program. A form is listed only if a pharmacy that can ship there carries it and state rules allow it.
- Delete any state whose cells cannot be confirmed. Do not list a state as “coming soon.”
- Re-verify at least monthly and whenever licensure, a pharmacy or a state rule changes. Update “Last verified.”
State | Clinician availability | Medication forms available | Notes |
|---|---|---|---|
Alabama | [VERIFY] | [VERIFY] | Minimum age 19. |
Alaska | [VERIFY] | [VERIFY] | |
Arizona | [VERIFY] | [VERIFY] | |
Arkansas | [VERIFY] | [VERIFY] | |
California | [VERIFY] | [VERIFY] | Oral and sublingual weight-loss forms are not offered in California. [VERIFY] |
Colorado | [VERIFY] | [VERIFY] | |
Connecticut | [VERIFY] | [VERIFY] | [VERIFY: state board position on compounded semaglutide and tirzepatide] |
Delaware | [VERIFY] | [VERIFY] | |
District of Columbia | [VERIFY] | [VERIFY] | |
Florida | [VERIFY] | [VERIFY] | |
Georgia | [VERIFY] | [VERIFY] | |
Hawaii | [VERIFY] | [VERIFY] | |
Idaho | [VERIFY] | [VERIFY] | |
Illinois | [VERIFY] | [VERIFY] | |
Indiana | [VERIFY] | [VERIFY] | |
Iowa | [VERIFY] | [VERIFY] | |
Kansas | [VERIFY] | [VERIFY] | |
Kentucky | [VERIFY] | [VERIFY] | |
Louisiana | [VERIFY] | [VERIFY] | |
Maine | [VERIFY] | [VERIFY] | |
Maryland | [VERIFY] | [VERIFY] | |
Massachusetts | [VERIFY] | [VERIFY] | |
Michigan | [VERIFY] | [VERIFY] | |
Minnesota | [VERIFY] | [VERIFY] | |
Mississippi | [VERIFY] | [VERIFY] | Minimum age 21. |
Missouri | [VERIFY] | [VERIFY] | |
Montana | [VERIFY] | [VERIFY] | |
Nebraska | [VERIFY] | [VERIFY] | Minimum age 19. |
Nevada | [VERIFY] | [VERIFY] | |
New Hampshire | [VERIFY] | [VERIFY] | |
New Jersey | [VERIFY] | [VERIFY] | |
New Mexico | [VERIFY] | [VERIFY] | |
New York | [VERIFY] | [VERIFY] | [VERIFY: New York telehealth requirements] |
North Carolina | [VERIFY] | [VERIFY] | |
North Dakota | [VERIFY] | [VERIFY] | |
Ohio | [VERIFY] | [VERIFY] | [VERIFY: state board position on compounded semaglutide and tirzepatide] |
Oklahoma | [VERIFY] | [VERIFY] | |
Oregon | [VERIFY] | [VERIFY] | |
Pennsylvania | [VERIFY] | [VERIFY] | |
Rhode Island | [VERIFY] | [VERIFY] | |
South Carolina | [VERIFY] | [VERIFY] | |
South Dakota | [VERIFY] | [VERIFY] | |
Tennessee | [VERIFY] | [VERIFY] | |
Texas | [VERIFY] | [VERIFY] | |
Utah | [VERIFY] | [VERIFY] | |
Vermont | [VERIFY] | [VERIFY] | |
Virginia | [VERIFY] | [VERIFY] | |
Washington | [VERIFY] | [VERIFY] | |
West Virginia | [VERIFY] | [VERIFY] | |
Wisconsin | [VERIFY] | [VERIFY] | |
Wyoming | [VERIFY] | [VERIFY] |
From: Block 9. AI assistant disclosure (one line)
Notes
- Show it as the first message and keep a link visible while the window is open.
- Optional second sentence, only if the code confirms it: “Your messages stay in your browser and are not sent to WellPeps.” The brief says the assistant makes no network calls; confirm nothing is stored or logged before using it.
- Register item LS9-ASSISTANT-SURFACE-CONTROLLED: the assistant answers clinical questions today with no reviewer-visible control.
From: Block 10. Privacy and cookie banner (one line)
Rules for Variant B
- Accept and Reject have equal size, color and prominence. No pre-checked boxes. No tracker fires before the visitor chooses.
- Honor Global Privacy Control as a rejection.
- Do not load analytics or ad tools on pages or steps that reveal a health condition or treatment unless the visitor has consented. Washington’s My Health My Data Act, Nevada SB 370 and Connecticut’s consumer health data law require separate consent.
- Describe the real tools in the Cookie and Tracking Technologies Notice and the Privacy Policy.
From: Block 12. How the care team works (one paragraph)
Notes
- This paragraph does not name the Practice, the management-services partner or the technology platform, because naming the Practice needs its written consent (the agreement with the Practice section 20). How WellPeps Works, the Financial Relationship Disclosure and Acknowledgment and the Notice of Privacy Practices carry the names once consent is in hand.
- “Usually online” matches the asynchronous review model. Change it if live visits become routine.
Part A. How to use this document
Each block below is copy that can be pasted as written. Text in highlighted brackets is a fact or a decision that is still missing. Blocks use the standard terms “WellPeps, a Wyoming corporation,” “independent licensed clinicians,” “state-licensed pharmacies” and “a prescription is not guaranteed.” Cross-references name other WellPeps documents by their exact titles.
Claims rules that apply to every block
- Never call a compounded medication FDA-approved, “generic,” “the same as,” “equivalent to” or “identical to” a brand medication. Do not use brand names to describe compounded products.
- Say “state-licensed pharmacy.” Never say “FDA-registered,” “FDA-approved pharmacy” or “FDA-inspected.”
- Never say “HIPAA compliant,” “guaranteed,” “safe,” “natural” or “risk-free.” Do not publish weight-loss numbers or any outcome number.
- Write “Prescription required; a prescription is not guaranteed” wherever a treatment is mentioned.
- “Free” is allowed only for the health assessment, with the full-refund rule next to it.
- Do not name the Practice, the management-services partner or the technology vendor in patient-facing copy unless the contract allows and written consent is in hand.
- Never write “all 50 states.” Use the States We Serve page.
- A disclaimer cannot fix content that contradicts it. Dosing instructions do not belong in educational content.
Where each block goes
# | Block | Where it goes | Reviewer |
|---|---|---|---|
1 | Site footer disclosure | Footer of every page (Footer.astro). Short form for mobile, ads and email footers. | Counsel |
2 | Medical Disclaimer page | New page /medical-disclaimer. Linked from the footer legal links, every program page and the checkout. | Counsel, Medical director |
3 | Educational content disclaimer | End of every Learning Center article (template), eBook front matter and last page, and the eBook request form. | Compliance review, Medical director |
4 | Compounded-medication statement | Short form on product cards and ads. Standard form on program pages, the quick view and the footer. Long form links to the Compounded Medication Disclosure and Consent. | Medical director, Counsel |
5 | Prescription-required sentence and program variants | Every page, card, ad or email that mentions a treatment. Variants on the matching program page. | Medical director |
6 | Results and testimonial disclaimer; Review and Testimonial Policy | Next to any review, story or results statement. The policy is a page linked from the footer and from review sections. | Counsel |
7 | About and Contact legal block | New Contact page, the About and Why WellPeps pages, and the footer. | Counsel, WellPeps |
8 | States We Serve page | New page /states-we-serve. Linked from the footer, every program page and the checkout. | Counsel, Practice, Pharmacies |
9 | AI assistant disclosure | The first line of the site assistant window, with a link to the AI Use Disclosure. | WellPeps, Counsel |
10 | Privacy and cookie banner | First visit on every page. Footer link “Your Privacy Choices.” | Counsel (privacy) |
11 | Claim replacements | Footer badge, config coverage string, program pages, FAQs, the assistant knowledge base and the home page content data. | Counsel |
12 | How the care team works | How WellPeps Works page, the home page journey section, program pages and the FAQ. | Counsel, Practice |