What we are watching, and why it matters to you.

Corporate practice of medicine is still decided state by state

A management services structure that clears cleanly in one state can put a practice out of business in the next. The variation is not marginal. It goes to who may own the clinical entity, who may control clinical decisions, and how the management fee itself may be calculated. For anyone expanding across state lines, the structure has to be mapped jurisdiction by jurisdiction before the first patient is seen, because unwinding it afterwards is the expensive version.

How the firm handles this →

The compounding position moved twice in 2026, and neither move settled it

Under section 503A of the Federal Food, Drug, and Cosmetic Act a bulk drug substance is eligible for compounding only if it meets a USP or National Formulary monograph, is a component of an approved drug, or appears on the FDA’s 503A bulks list. In April 2026 the FDA announced that twelve substances, BPC-157 among them, would come out of Category 2 of its interim bulks policy. On 23 and 24 July 2026 the Pharmacy Compounding Advisory Committee recommended six of them for the list. Neither step puts a substance on the list. That takes notice-and-comment rulemaking, which the FDA had not completed as of August 2026.

Peptide practices tend to run into trouble in three predictable places: where the product is sourced, how the compounding relationship is documented, and what the marketing says the product does. The first two are structural and fixable in advance. The third is the one most often handed to a marketing team with no legal review, and it is the one regulators read first.

How the firm handles this →

Who may own a clinic or a med spa in North Carolina

The North Carolina Medical Board’s position statement on the corporate practice of medicine, amended September 2025, is that a business practicing medicine in this state must be owned in its entirety by holders of active North Carolina licenses, or by one of the combinations G.S. 55B-14 permits, with recognized exceptions for hospitals and hospital-owned practices, health maintenance organizations, public health clinics and charitable nonprofits. Nothing in that list is an investor.

Investors regularly assume an MSO lets them own a medical practice. It does not. What it can do is contract for the non-clinical side of the operation, billing, staffing, premises, technology and marketing, on terms that are genuinely arm’s length. The distinction sounds academic until a state board asks who signs off on clinical protocols, and the answer is in the management agreement rather than the medical record.

Clinics, med spas & longevity → How the firm handles this →

Ownership changes without triggering a license review

In most licensed markets, a change of ownership above a threshold triggers regulatory review, and review means delay. Whether a transaction crosses that threshold is usually a question of structure rather than economics, which means it is a question that can be answered before the deal is papered rather than after the filing. Timing and regulator communication ahead of filing do most of the work.

How the firm handles this →

Debt is often the cheaper answer, and nobody volunteers it

Owners with real revenue frequently have credit options they have never priced, and go straight to selling equity because that is the conversation everyone else is having. Dilution should be a decision made against an alternative, not a default. Running the covenant analysis alongside the equity case usually takes a week and occasionally changes the whole plan.

How the firm handles this →

Handshake equity is the most common repair we make

Early contributors were promised something. Four years later nobody agrees on what, there is nothing in writing, and a diligence request is due Friday. Reconstructing the history and papering it cleanly is routine work if it starts early, and a genuine threat to a round if it starts late.

How the firm handles this →