AHD-COMP-001 — Regulatory Map v0.1

Status: DRAFT v0.1 (CRITICAL findings from NEXUS Seat 03 — read AHD-RESEARCH-SYNTHESIS-v1.0 §SEAT 03 for the full 5-landmine framework)

Headline Findings (from NEXUS regulatory research)

Five Critical Landmines

1. HHA Licensure Required in All 3 States — adds $30K + 60-120 days per state
2. CA AB5 Likely Makes 1099 RN Model Illegal — must shift to W-2 employees
3. Controlled Substance Chain of Custody — 1099 RNs cannot transport Schedule III/IV
4. EKRA Federal Criminal Exposure — $200K + 10 years per occurrence on referrals
5. Multi-State MD Licensure + DEA Required — Elizabeth needs separate license + DEA in each state

State-by-state

• California: H&S §11834 substance abuse facility licensure; H&S §1726 HHA; AB5 employee classification; CMIA stricter than HIPAA
• New York: OASAS may assert jurisdiction; LHCSA or CHHA home care licensure; full state medical license required for prescribing
• Florida: DCF Chapter 397 likely jurisdiction; AHCA home health licensure; §817.505 patient brokering felony

Helpful Findings

• DEA telemedicine flexibilities extended through Dec 31, 2026
• Buprenorphine via audio-only telemedicine permanently authorised
• Florida is IMLC member (expedited multi-state licensure pathway)

Recommended Strategy (CA-only Y1)

Per Research Synthesis v1.0 recommendation: launch CA-only Y1 with full HHA licensure + employee model. Defer NY and FL to Y2 once CA operating model is proven.

Validation Path

Counsel review by Nelson Hardiman LLP (or alternative from shortlist) is the gating step before any further capital deployment.