Under the supplied matrix, each video visit is governed by the state where the patient is physically located.

## 1. Video antidepressant care by state

An antidepressant is a **noncontrolled** medication, so the noncontrolled pathways apply.

| State | Clinician | Why |
|---|---|---|
| Alder | **Dr. Lee** | Dr. Lee holds a full Alder license. Alder recognizes no compact privilege or registration. Video evaluation is permitted for noncontrolled medication. |
| Birch | **Dr. Lee** | Dr. Lee holds a recognized Birch compact privilege, and Birch permits video evaluation for noncontrolled medication. |
| Cedar | **NP Vale** | Vale holds a full Cedar license, and Clearpath holds the required Cedar entity permit. Video evaluation is permitted for noncontrolled medication. Dr. Lee is not licensed in Cedar. |
| Dune | **Dr. Lee** | Dr. Lee holds an approved Dune telehealth registration, which is sufficient for noncontrolled treatment. Vale has no Dune authority. |

So Clearpath **can** launch video antidepressant care in all four states, using the correct clinician for each state.

## 2. Entity-permit requirements

Only Cedar imposes a **telehealth company entity permit** requirement in the supplied matrix.

- Cedar: Clearpath holds the required **Cedar entity permit**.  
- Cedar also requires an individual full Cedar license, and Vale has it.  
- Alder, Birch, and Dune do not impose an entity permit requirement in the supplied matrix.

Clearpath therefore satisfies the entity-permit requirements shown in the matrix.

## 3. New-patient video stimulant prescribing

A stimulant is a controlled medication, so the controlled-substance conditions apply.

| State | Video stimulant first prescribing for new patients? | Reason |
|---|---|---|
| Alder | **No under the proposed video-only pathway** | Alder requires that the **same practice** conducted an in-person examination within the preceding 12 months. A new video-only patient has no such Clearpath in-person exam. |
| Birch | **Yes** | Dr. Lee may use the Birch compact privilege, Birch permits video evaluation for controlled substances, and the Birch PMDB must be checked and documented before each stimulant prescription. |
| Cedar | **No under the proposed video-first pathway** | Cedar requires the **first controlled prescription** to be preceded by an in-person examination by the prescribing practice. A new video-only patient does not satisfy that condition. |
| Dune | **No** | Dr. Lee’s Dune telehealth registration cannot be used for controlled substances, and Clearpath has no fully Dune-licensed clinician. |

## 4. Outside primary-care examinations: Alder and Cedar

An outside primary-care clinician’s in-person examination does **not** satisfy Alder or Cedar.

General Rule 7 says an unaffiliated outside clinician satisfies a state condition only if the matrix expressly says so.

- Alder requires an exam by the **same practice**, not by an outside clinician.
- Cedar requires an exam by the **prescribing practice**, not by an outside clinician.

Therefore, Clearpath cannot use the proposed outside-primary-care examination to qualify patients for stimulant prescribing in Alder or Cedar.

In Birch, no in-person condition exists, so the outside exam is irrelevant. In Dune, it cannot overcome the controlled-substance telehealth bar/absence of a full Dune license.

## 5. Lawful stimulant-renewal pathways

| State | Lawful video renewal pathway | Outside-PCP renewal proposal |
|---|---|---|
| Alder | A stimulant renewal may be lawful only if Clearpath’s own practice conducted an in-person exam within the preceding 12 months, and Dr. Lee provides the video visit under the Alder license. | **Blocked** — outside PCP is not “same practice.” |
| Birch | Dr. Lee may provide video renewals under the Birch compact privilege. Birch has no in-person exam requirement. The Birch PMDB must be checked and documented before each stimulant prescription. | **Allowed**, but the outside PCP exam is not the legal basis. |
| Cedar | Video renewals are lawful only for patients whose first controlled prescription was preceded by a Clearpath in-person exam, and only within 12 months after that exam. Vale must be the Cedar clinician. | **Blocked** — outside PCP is not the “prescribing practice.” |
| Dune | **No lawful Clearpath stimulant renewal pathway** under the current facts. Dr. Lee’s Dune registration cannot prescribe controlled substances by telehealth, and Clearpath has no full Dune-licensed clinician. | **Blocked** |

## 6. Required location, consent, and monitoring steps

The platform must enforce these steps:

1. **Verify and document patient physical location at the start of every video visit.** The patient’s location determines which state’s licensure and prescribing rules apply.

2. **Obtain telehealth informed consent before the first telehealth service and document it in the record.**

3. **Birch: check and document the state prescription-monitoring database before every stimulant prescription**, including renewals. The platform should make this a hard stop.

4. **Alder: track the Clearpath in-person exam date and block stimulant prescribing if the exam is more than 12 months old or was done by an outside clinician.**

5. **Cedar: track the Clearpath in-person exam and first controlled prescription; allow video renewals only within 12 months after that exam; block outside-PCP exams from unlocking controlled prescriptions.**

6. **Dune: block all controlled-stimulant tele-prescribing by Dr. Lee** because his Dune registration is noncontrolled-only and Clearpath has no full Dune-licensed clinician.

## 7. Services the platform must block

- **Video antidepressant care:** allow in all four states.
- **Video stimulant first prescribing:** allow in **Birch only** under Dr. Lee, with PMDB checks.
- **Video stimulant first prescribing:** block in **Alder, Cedar, and Dune** as proposed.
- **Video stimulant renewals based on outside-PCP exams:** block in **Alder, Cedar, and Dune**.
- **Alder/Cedar hybrid path:** allow only if Clearpath’s own practice performs the required in-person exam and the platform verifies it.

## 8. Accurate marketing claim

Clearpath may **not** advertise “fully virtual ADHD treatment in all four states.”

An accurate claim would be:

> “Clearpath offers video antidepressant management in all four states. Fully virtual stimulant/ADHD medication treatment is available only in Birch. In Alder and Cedar, stimulant treatment requires an in-person exam with Clearpath before controlled treatment, with video renewals as permitted. Dune is not available for Clearpath telehealth stimulant treatment.”