# Clearpath Rollout Map — Four States

## 1. Who may provide video antidepressant (noncontrolled) care

| State | Authorization required by matrix | Qualified Clearpath clinician |
|---|---|---|
| Alder | Full Alder license only (no compact/registration recognized) | **Dr. Lee only** |
| Birch | Recognized compact privilege sufficient | **Dr. Lee only** |
| Cedar | Full Cedar license **and** company entity permit | **NP Vale only** |
| Dune | Approved Dune telehealth registration sufficient | **Dr. Lee only** |

Consequences of Rule 6 (one authorization ≠ another):
- Dr. Lee **cannot** see Cedar-located patients at all — no Cedar license, and neither the Birch compact privilege nor the Dune registration substitutes.
- NP Vale **cannot** see Alder, Birch, or Dune patients for anything, including antidepressants.
- Dr. Lee's Dune registration covers noncontrolled treatment only; it never converts to prescribing authority for the stimulant.
- Cedar is single-covered (Vale). If Vale is unavailable, Cedar service stops; that is a staffing risk, not a legal workaround.

## 2. Entity-permit compliance

Only Cedar's matrix imposes an entity permit, and Clearpath holds it — so the entity requirement is satisfied. But under Rule 8 the permit is only half of Cedar: **every** Cedar encounter also needs an individually Cedar-licensed clinician (Vale). The Cedar permit gives Dr. Lee nothing. Alder, Birch, and Dune impose no entity permit in the matrix, so none is required; conversely, having no Birch or Dune facility is irrelevant to those states' rules but is fatal to Alder/Cedar-style in-person conditions elsewhere.

## 3. New-patient video stimulant prescribing (controlled)

| State | Fully virtual new-patient stimulant? | Why |
|---|---|---|
| Alder | **No** | Requires an in-person exam **by the same practice** within the prior 12 months; a new patient has none. |
| Birch | **Yes — Dr. Lee** | Video evaluation permitted for controlled medication; compact privilege suffices; PDMP check required and documented before each prescription. |
| Cedar | **No** | First controlled prescription requires an in-person exam **by the prescribing practice**. |
| Dune | **No — prohibited outright** | A registrant may never prescribe a controlled substance by telehealth; controlled prescribing needs a full Dune license, and Clearpath has no Dune-licensed clinician. There is no cure available today. |

**Birch is the only state where "video-only ADHD start" is lawful.**

## 4. Does an outside primary-care in-person exam satisfy Alder or Cedar?

**No — in neither state.** Alder requires the exam by "the same practice"; Cedar requires it "by the prescribing practice." Under Rule 7, an unaffiliated outside clinician's exam counts only if the matrix expressly says so, and neither state says so. Proposal 3 is therefore unlawful as written in Alder and Cedar. (In Birch the outside exam is unnecessary; in Dune it is worthless because the bar is absolute.)

## 5. Lawful stimulant-renewal pathways

- **Alder (hybrid):** Dr. Lee (full Alder license) performs an in-person examination at Clearpath's Alder clinic. Video stimulant prescribing/renewal is then permitted, but each prescription must fall within 12 months of a same-practice in-person exam — i.e., a rolling lookback requiring re-examination at least annually.
- **Birch (fully virtual):** Dr. Lee may evaluate, start, and renew by video indefinitely, with a documented Birch PDMP check before **each** prescription.
- **Cedar (hybrid):** NP Vale performs the in-person exam at Clearpath's Cedar clinic (entity permit + Cedar license both present). Video renewals are then permitted for 12 months from that exam; a new in-person exam is needed to continue past 12 months.
- **Dune:** **No pathway.** No in-person visit, no outside exam, and no registration-based workaround can authorize it.

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

1. **Location:** Verify and document the patient's physical location at the start of every visit. The patient's state governs the encounter, so the platform must re-run the licensure/prescribing test each visit — e.g., a Cedar patient who travels to Birch may only be seen by someone with Birch authority (Lee, not Vale); an Alder patient who travels to Dune cannot receive a stimulant prescription that day.
2. **Consent:** Obtain and document telehealth informed consent before the first telehealth service, per each state's baseline rule.
3. **Evaluation:** Conduct an adequate clinical evaluation in the modality that state permits (video is adequate for antidepressants in all four; for stimulants, video suffices only in Birch, and only post-exam in Alder/Cedar).
4. **Monitoring:** Birch stimulant prescriptions require a PDMP query plus documentation of the check before each prescription. No PDMP condition is stated for the other states; the platform's Birch database connection cannot be repurposed as compliance evidence elsewhere.
5. **Documentation to retain:** date/place/clinician of the qualifying same-practice in-person exam (Alder, Cedar), running 12-month expiry dates, PDMP check records (Birch).

## 7. Services the platform must hard-block

- Any encounter by **NP Vale** with a patient located in Alder, Birch, or Dune (including antidepressants).
- Any encounter by **Dr. Lee** with a patient located in Cedar.
- **All** stimulant prescribing for Dune-located patients, by either clinician, new or renewal.
- **Video first-fill stimulant prescribing in Alder and Cedar** absent a documented in-person exam by Clearpath within 12 months.
- Acceptance of an **outside primary-care exam record** as the unlocking event for Alder or Cedar stimulant prescribing.
- Any **Birch stimulant prescription without a recorded PDMP check** for that prescription.
- Any **stimulant renewal where the Clearpath in-person exam is more than 12 months old** (Alder, Cedar).
- Any visit lacking documented location verification, or a first telehealth visit lacking documented consent.

## 8. Accurate rollout and permissible marketing

**Rollout:**
- **Alder:** Antidepressants fully virtual (Dr. Lee). ADHD stimulants hybrid — one in-person visit at the Alder clinic first, then video for up to 12 months, re-examined annually.
- **Birch:** Antidepressants and ADHD stimulants fully virtual (Dr. Lee), with PDMP check on every stimulant prescription.
- **Cedar:** Antidepressants fully virtual (NP Vale, under the Cedar entity permit). ADHD stimulants hybrid — first in-person exam at the Cedar clinic, then video renewals for 12 months.
- **Dune:** Antidepressants only, fully virtual (Dr. Lee's registration). **No** ADHD stimulant service of any kind.

**Marketing:** "Fully virtual ADHD treatment in all four states" is false and must be withdrawn. A defensible claim is:

> "Virtual depression care in all four states. Virtual ADHD care in Birch; in Alder and Cedar, ADHD treatment begins with one in-person visit at our local clinic and then continues by video. ADHD stimulant treatment is not available in Dune."