Draft v0.1 · Document A8

Medical Disclaimer and Site-Wide Disclosures

The approved disclosure copy blocks: medical disclaimer, compounded-medication statement, prescription-required lines.

Draft for attorney review. Not in effect.

This is version 0.1, prepared October 1, 2026. It has not been approved, and nothing on this page binds anyone yet. It is shown here so counsel can read it in place on the site. Items in [brackets] are still open:

  • [Amber] a lawyer or the medical director must decide or confirm it.
  • [Red] WellPeps supplies a fact (an address, an email, a date, a fee).
  • [Blue] the web team builds or fills it.

Each section has its own address: choose it in “On this page”, then copy the address from the browser, so a comment can point to an exact place. Technical instructions and drafting notes are collected at the end of the document, under “Technical and drafting notes”; the reviewer notes and open-items tables are kept in the separate drafting file.
All draft documents

On this page (13 sections)
  1. Block 1. Site footer disclosure
  2. Block 2. Medical Disclaimer (page copy)
  3. Block 3. Educational content disclaimer (Learning Center and eBooks)
  4. Block 4. Compounded-medication statement (site level)
  5. Block 5. Prescription-required sentence and program variants
  6. Block 6. Results and testimonial disclaimer; Review and Testimonial Policy
  7. Block 7. About and Contact legal block
  8. Block 8. States We Serve (page template)
  9. Block 9. AI assistant disclosure (one line)
  10. Block 10. Privacy and cookie banner (one line)
  11. Block 11. Replacing the “HIPAA Compliant” badge and the “Licensed Providers in All 50 States” claims
  12. Block 12. How the care team works (one paragraph)
  13. Technical and drafting notes

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]

1.
This website is general information. Everything on wellpeps.com, including articles, guides, eBooks, videos, product pages, FAQs and the site assistant, is for general information and education. It is not medical advice, diagnosis or treatment. Do not use it to decide whether to start, change or stop a medicine, or to delay getting care.
2.
Visiting this site does not make you a patient. Reading this site, chatting with the site assistant, or contacting WellPeps support does not create a clinician-patient relationship. That relationship begins only if an independent licensed clinician accepts you as a patient after reviewing your health information in the patient portal and you have agreed to the telehealth consent. A clinician may decline to treat you.
3.
This site is not for emergencies. If you think you may have a medical emergency, call 911 or go to the nearest emergency room. If you are thinking about harming yourself, call or text 988. For a possible overdose or wrong dose, call Poison Control at 1-800-222-1222. WellPeps support and the patient portal are not monitored for emergencies.
4.
What WellPeps is and is not. WellPeps, a Wyoming corporation (“WellPeps”), offers education, enrollment, customer support and other non-clinical services. WellPeps is not a medical provider, a doctor’s office or a pharmacy. WellPeps does not practice medicine, diagnose, prescribe, compound or dispense medication, and does not make treatment decisions.
5.
Who provides care. Medical care is provided by independent licensed clinicians of [PRACTICE NAME] (“the Practice”), which is separate from WellPeps. Medications are prepared and shipped by independent state-licensed pharmacies. Read How WellPeps Works for details.
6.
A prescription is required and is not guaranteed. A licensed clinician decides whether a prescription is medically appropriate for you. Paying for a plan does not guarantee a prescription. If your clinician does not prescribe, you get a full refund, as the Refund, Cancellation and Auto-Renewal Policy explains.
7.
Compounded medications. Some prescriptions are compounded. A compounded medication is made by a state-licensed pharmacy for one patient, based on a clinician’s prescription. Compounded medications are not FDA-approved. FDA does not review them for safety, effectiveness or quality before they are sold. A compounded medication is not a generic version of an FDA-approved medicine, and you should not assume it is the same as, or can be swapped for, an FDA-approved medicine. Your clinician decides whether a compounded medication is right for you. You can ask about FDA-approved options at any time. Read the Compounded Medication Disclosure and Consent for more.
8.
Off-label use. Some medicines may be prescribed for a use that FDA has not approved. This is called “off-label” use. It is lawful when a clinician decides it is appropriate. Your clinician will tell you if it applies to you.
9.
Results vary. People respond to treatment differently. WellPeps does not guarantee any result. Reviews and stories on this site reflect individual experiences. See the Review and Testimonial Policy.
10.
Educational content and links. Our content may be out of date or may not apply to you. Links to other sites are for your convenience. We do not control those sites and do not endorse them.
11.
The site assistant is automated. It is not a person or a clinician. It can be wrong. Do not rely on it for medical decisions. See the AI Use Disclosure.
12.
Availability. Services are offered only in certain states, and some medications may not be available in your state. See States We Serve.
13.
Your part. Give your clinician complete and accurate information. Follow your prescription label and your clinician’s instructions. Tell your clinician about any side effect.
14.
Limits and changes. The Website Terms of Use explain limits of liability. We may update this page, so check the date above.
15.
Questions. Write to [SUPPORT EMAIL]. For medical questions, message your clinician in the patient portal at [PORTAL URL].

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)

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]

1.
We want honest reviews. We welcome honest feedback from our patients and visitors, good and bad.
2.
No gag clauses. Nothing in our Website Terms of Use, Patient Terms of Service and Payment Agreement, or any other form we ask you to accept stops you, penalizes you or discourages you from posting an honest review or sharing your experience anywhere, including a negative one.
3.
We do not hide reviews because they are negative. We ask every patient the same way. We do not screen who gets asked, and we do not suppress or hide a review because of its rating. We may remove content that is unlawful, threatening or harassing, reveals someone else’s private information, is spam, or gives medical or dosing instructions. We apply these rules to positive and negative reviews alike.
4.
We do not buy good reviews. We do not pay for, or offer anything of value for, a positive review, or anything that depends on the rating or what you say. We do not offer incentives for reviews at this time.
5.
No fake reviews. We do not write, buy or generate fake reviews or testimonials, and we do not use artificial intelligence to create reviews. Employees, owners and their families do not post reviews of WellPeps unless the connection is clearly stated next to the review.
6.
No result numbers and no before-and-after photos. We do not publish weight-loss or other outcome numbers, and we do not publish before-and-after photos. A story shows one person’s experience. It does not show what you should expect.
7.
Creators, affiliates and influencers. People who promote WellPeps must have a written agreement, must clearly say they have a connection to WellPeps (for example “ad” or “paid partnership”) at the start of the post, and may use only claims we have approved. They must say that a prescription is required and not guaranteed, and they may not describe a compounded medication by a brand name.
8.
Your privacy. We do not publish your name, photo, health information or story without your written permission. Where the information comes from your care records, we also need a signed authorization. See the HIPAA Authorization Forms. You can withdraw your permission at any time by writing to [SUPPORT EMAIL], and we will stop using your story going forward.
9.
Reviews on other sites. We do not control reviews on other websites. We do not ask anyone to remove an honest review.
10.
Concerns. If you think a review or promotion of WellPeps is misleading, write to [SUPPORT EMAIL].

Copy

Block 8. States We Serve (page template)

Copy: page introduction

Copy: footnotes under the table

Block 9. AI assistant disclosure (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

  1. 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.
  2. Say “state-licensed pharmacy.” Never say “FDA-registered,” “FDA-approved pharmacy” or “FDA-inspected.”
  3. Never say “HIPAA compliant,” “guaranteed,” “safe,” “natural” or “risk-free.” Do not publish weight-loss numbers or any outcome number.
  4. Write “Prescription required; a prescription is not guaranteed” wherever a treatment is mentioned.
  5. “Free” is allowed only for the health assessment, with the full-refund rule next to it.
  6. 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.
  7. Never write “all 50 states.” Use the States We Serve page.
  8. 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

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