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Learn library · GLP-1 Clinic Startup Checklist

THE GLP-1 CLINIC STARTUP CHECKLIST, SECTION BY SECTIONA dense, printable audit of the line items a cash-pay metabolic clinic has to clear before it opens — grouped by function, with the ones people most often miss marked.

Educational overview · Approx. 14 min read · illustrative, not advice

A dense, printable audit of the line items a cash-pay metabolic clinic has to clear before it opens — grouped by function, with the ones people most often miss marked.

Use this as a checklist, not as a plan

This page is built to be printed and marked up. It is an inventory, not a narrative. If you want the sequence — what happens first, what depends on what, how the phases actually order themselves — read the companion walkthrough on how to start a metabolic reset clinic instead. Duplicating that arc here would waste your time. Read that one for the story; use this one for the audit.

Two standing caveats before the first box. First, nothing on this page is legal, medical, tax or financial advice. Every item below that says verify means verify with your own counsel, licensed in the state where you intend to operate, because the answers differ by state and they are moving. Second, there is no revenue figure anywhere on this page and there will not be one. Atlas has no Franchise Disclosure Document, so we publish no earnings, margin, break-even or payback numbers at any time. Cost lines appear because costs are knowable; the other half of that equation is yours to model with your own accountant.

Legal, entity and licensure

Structure comes first because it is the most expensive thing to reverse. Everything downstream — banking, contracts, insurance, the ownership of the medical record — inherits whatever you decide here, and unwinding it after you have members enrolled is materially harder than getting it right cold.

  • Operating entity formed, in the state of operation, with an operating agreement that says who decides what.
  • Verify how the corporate practice of medicine doctrine applies to you. It is a body of state-level rules barring unlicensed persons and corporations from owning or controlling a medical practice or employing physicians for clinical care, intended to preserve independent medical judgment. It varies by state; do not rely on any national count of which states have it.
  • If you are not a licensed clinician: the standard structural response is a clinician-owned professional entity separated from a management services organisation that handles non-clinical functions. Verify the specifics with counsel.
  • COMMONLY MISSED — the management services agreement itself. Enforcement risk turns on how much control the management entity exercises over clinical operations and professional judgment, not on whether the paperwork exists. 2025 state activity moved toward tightening: Massachusetts enacted management-services-organisation ownership transparency requirements, and Oregon, Washington and California saw strengthening bills introduced.
  • State medical licence for every clinician, in every state where members are located. Practice of medicine is generally deemed to occur where the patient is, not where the clinician sits.
  • Interstate Medical Licensure Compact evaluated as a multi-state pathway — it covered up to 43 member states as of March 2026.
  • State controlled-substance registration where applicable, checked per state.
  • DEA practitioner registration where applicable: $888 per three-year term under 21 CFR 1301.13.
  • Professional liability cover bound, with tail coverage understood. Premiums have risen for a seventh consecutive year; the share of reported premiums increasing year over year climbed from 13.7% in 2018 to nearly 40% in 2025.
  • COMMONLY MISSED — pricing liability cover by market before you sign a lease. The reported 2025 manual premium for an internal medicine physician in Miami-Dade County, Florida was $59,736; that is a high-cost outlier, not a national typical, and the only way to know your number is to quote your own market.
  • General liability, cyber and employment practices cover reviewed as a set, not bought piecemeal.
  • Registered agent, DBA registration, and a corporate name cleared against state and federal marks before any brand spend.
  • Written policy on who is the custodian of the medical record if a clinician departs.

Clinical: who is actually practicing medicine

The single question a regulator, an insurer and a plaintiff's lawyer will all ask in different words: who exercised medical judgment, and were they licensed to. Every line below exists to make that answer boring.

  • Named medical director, licensed in state, with a written scope that describes actual duties rather than a title.
  • Scope-of-practice, supervision and collaborative-agreement requirements for nurse practitioners and physician assistants verified state by state.
  • Written eligibility and exclusion criteria authored by clinicians, versioned and dated.
  • Individualised evaluation documented for every patient of the medical entity — not a standing order applied to an intake list.
  • Contraindication and interaction screening built into intake, not left to a free-text box.
  • Baseline and follow-up laboratory ordering pathway, with a named reviewing clinician.
  • Titration and refill policy owned by the clinical side. Marketing does not author it and does not edit it.
  • Adverse-event capture and reporting pathway, including how a report reaches the manufacturer or FDA.
  • Escalation and after-hours pathway written down and given to the patient in writing.
  • Record retention schedule per state, plus a release-of-records process.
  • COMMONLY MISSED — a written policy on what happens clinically when a member cannot continue, whether for cost, tolerability or supply. That decision gets made under pressure if you have not made it in advance.

Technology and data

Most of this stack is commodity. The parts that are not commodity are the seams between systems, which is where consent, records and personal health information leak. The trade-offs between a clinic-anchored build and a distributed one are worked through in the comparison of telehealth versus in-clinic metabolic care; the checklist below assumes you have already picked a side.

  • Electronic health record selected, with an export path you have actually tested before go-live.
  • Telehealth platform with a signed business associate agreement in place.
  • Electronic prescribing configured, including EPCS where controlled substances are in scope.
  • Payment processing approved for your category, with the underwriting conversation had honestly up front.
  • CRM and scheduling connected to intake without copy-paste steps between them.
  • Secure messaging that is not personal email and not a consumer chat app.
  • Consent capture — telehealth consent, financial consent, communications consent — timestamped and retrievable per person.
  • A written list of every vendor that touches personal health information, with the corresponding agreements attached to it.
  • COMMONLY MISSED — advertising and analytics tags on patient-facing pages. Third-party tracking placed on intake, scheduling or portal pages is one of the most common ways a compliant clinical operation creates a disclosure problem for itself. Audit every tag, on every page behind the ad click.
  • Backup, access logging and offboarding process for staff accounts.
  • Uptime and support expectations for anything a member touches at 9pm.
  • Technology cost line budgeted. Commonly cited ranges put IT infrastructure and electronic records at roughly $10,000–$25,000 to establish and $500–$2,000 per month in subscriptions — widely repeated figures that we could not trace to an authoritative survey, so treat them as directional only.

Supply: the line most likely to change underneath you

Supply is where the last three years have punished operators who built a business on a channel rather than on a category. The compounded channel opened because of a shortage, and shortages end. What matters now is not which channel you like but whether your business survives your channel disappearing. If you have not thought about upstream dependency before, the primer on how supplement supply chains work covers the structural version of the same problem.

  • Channel decision documented, with the regulatory basis for it written down rather than assumed.
  • Know the timeline. FDA removed tirzepatide from the shortage list in December 2024, with compounders expected to cease by March 2025. FDA declared the injectable semaglutide shortage resolved on 21 February 2025; enforcement discretion ended 22 April 2025 for 503A pharmacies and 22 May 2025 for 503B outsourcing facilities.
  • COMMONLY MISSED — the live risk with its dates. On 30 April 2026 FDA proposed excluding semaglutide, tirzepatide and liraglutide from the 503B bulk drug substances list, finding no clinical need and expressly rejecting affordability and insurance access as constituting clinical need; the comment period was extended, with comments due 30 July 2026. Any plan that depends on that channel needs a written answer for the outcome.
  • Understand FDA's own stated position: a compounded product may contain the same active ingredient but is not the drug FDA reviewed and approved, and FDA does not evaluate specific compounded products for safety, effectiveness, manufacturing quality or consistency.
  • Enforcement posture noted: FDA has received hundreds of adverse event reports tied to compounded semaglutide and tirzepatide, including dosing-error reports, has warned about fraudulently labelled product naming pharmacies that do not exist, and issued more than 50 warning letters in September 2025 over statements it deemed false or misleading.
  • If compounded product is in scope, know what is in it. IQVIA reported in October 2025 that more than 80% of compounded GLP-1 prescriptions include supplemental ingredients.
  • Brand self-pay pricing tracked, because it sets the reference price your member is comparing against. Novo Nordisk's NovoCare Pharmacy lists Wegovy self-pay from $149 per month for the 1.5 mg or 4 mg oral doses for new patients, the standard pen from $199 per month for the first two months as a limited-time offer, and the 7.2 mg HD pen from $399 per month after introduction; pricing is stated as subject to change.
  • Direct-to-consumer policy shifts tracked: November 2025 White House agreements set $350 per month starting doses through TrumpRx from January 2026, trending toward $245 over two years.
  • Second source identified and contracted, or an explicit written decision not to have one.
  • COMMONLY MISSED — marketing assets that name a specific molecule. Every brochure, page and ad that hard-codes a product name becomes a reprint bill the day your channel changes.

Cost lines and financial controls

Below are cost items only. No revenue figure appears here, no margin is implied, and nothing on this page may be combined with anything else on this page to produce one. That restraint is deliberate and it is explained in the piece on what a royalty really costs, which deals with the same discipline from the other direction.

  • First-year startup and operating budget built from your own quotes. Commonly cited ranges of roughly $70,000–$500,000, with build-out $20,000–$60,000 and clinical equipment $15,000–$75,000, circulate widely but could not be traced to an authoritative survey. Use them to sanity-check a quote, never as a plan.
  • Understand that a telehealth-first or hybrid model shifts cost composition rather than reducing a stated total: it avoids build-out and clinical equipment lines while adding multi-state licensure and technology lines.
  • Licensure and registration costs priced per jurisdiction — they cannot be generalised.
  • Merchant processing terms, including reserve, chargeback ratio thresholds and what happens to your account if you cross them.
  • Written refund and cancellation policy, finalised before the first sale rather than after the first dispute.
  • COMMONLY MISSED — sales tax and nexus treatment for any supplement or retail product you ship. It is a separate regime from clinical services and it is state-specific.
  • Clinical and non-clinical funds separated in banking from day one, in a way that matches your entity structure rather than contradicting it.
  • Bookkeeping established before revenue, not reconstructed after it.
  • Payroll, contractor classification and any clinician compensation model reviewed by counsel for structural exposure.
  • A cost model you can defend line by line. The framing in the analysis of unit economics for metabolic care is the right level of rigour, and the same page is explicit about not supplying you with numbers to plug in.

Go-to-market and claim discipline

This is the section that generates regulatory letters, because it is the only section a stranger can read. Everything above is invisible to the public; every word below is evidence. The general framing lives in the overview of compliance basics for wellness businesses, and the way a cash-pay offer is structured to be honest about what is being sold is covered in the piece on cash-pay metabolic health program structure.

  • Written claim standard: no efficacy claims, no guarantees, no outcome promises, no implied medical result.
  • No before-and-after imagery used as an implied promise. Verify with counsel what your state and your ad platform permit.
  • Testimonials and reviews handled under current federal rules. The FTC's Rule on the Use of Consumer Reviews and Testimonials (16 CFR Part 465), published 22 August 2024 and effective 21 October 2024, prohibits fake and false reviews, insider reviews without disclosure of the material connection, and compensation conditioned on a particular sentiment.
  • COMMONLY MISSED — ad platform category policy. Weight-related advertising sits in a restricted category on most major platforms; account-level enforcement can remove your acquisition channel overnight and does not care that your claims were legally fine.
  • Landing page consent, privacy notice and communications opt-in wired to what you actually do with the data.
  • Speed-to-lead standard set and staffed, with a named owner.
  • Call handling script reviewed by clinical, not written by sales alone.
  • Pricing, terms and cancellation visible before payment rather than after it.
  • Local acquisition plan built from the ground rather than from national templates — the mechanics are covered in the guide to local marketing for wellness.
  • COMMONLY MISSED — a written policy on what staff may and may not say in DMs and comment replies. Most claim violations happen in casual channels, not in approved copy.
  • Complaint log, with a route from complaint to clinical review.

The items most commonly missed, in one list

If you print one thing, print this. Every item here appeared above, and each one is something we see cleared last or not at all.

  • The management services agreement scope — the control question, not the paperwork question.
  • Liability cover quoted in your actual market before signing anything with a term.
  • Custodianship of the medical record when a clinician departs.
  • A written clinical answer for members who cannot continue.
  • Advertising and analytics tags on patient-facing pages.
  • A dated, written position on the April 2026 proposed 503B bulks-list exclusion.
  • Marketing collateral that hard-codes a specific molecule.
  • Sales tax and nexus treatment for shipped product.
  • Ad platform category policy as an operating risk, not a creative constraint.
  • What staff may say in DMs, comments and text messages.

Where a licensed build compresses this list

None of the items above disappear because you license a build. Structure, licensure, insurance and clinical judgment stay with you and with your counsel — permanently, and by design, since Atlas Metabolic provides no medical services and employs no clinicians. Clinical care sits with a separately licensed medical entity, always.

What a build changes is how much of the non-clinical column you are assembling from scratch. The telehealth stack, the ordering system, member AI coaching, the brand kit and the operational playbooks arrive built rather than sourced, and the sequence and dependencies are already mapped. If you want to see what is and is not in scope before you talk to anyone, the breakdown of what turnkey actually means is the honest version, and the structural difference between a licence and a franchise is worked through in the comparison of franchise versus license.

Atlas takes a limited number of partner builds (Ask Atlas to put this in writing: partner slots per quarter), and the fit call decides in both directions — it is a qualification conversation, not a sales call, and a fair number of them end with us saying no. If you have worked this checklist and you want to know which parts of it a build actually removes, start the application. Bring the list with you.

Sources and status. Every figure on this page is listed with its publisher and whether it is directly verified or reasoned. Market data describes a market; it is not a statement about what any business will earn.
  • Milbank Memorial Fund issue brief (April 28, 2025) — The corporate practice of medicine doctrine comprises state-level rules prohibiting unlicensed persons and corporations from owning or controlling medical practices or employing physicians for clinical care; management services organisations are used to separate non-clinical functions; enforcement risk turns on the degree of control exercised over clinical judgment; Massachusetts enacted MSO ownership transparency requirements in 2025 and Oregon, Washington and California saw CPOM-strengthening bills introduced. (source) [VERIFIED]
  • Federation of State Medical Boards / Interstate Medical Licensure Compact Commission, as reported by Pullman & Comley — Medical practice is generally deemed to occur where the patient is located, so clinicians typically must be licensed in the patient's state; the Interstate Medical Licensure Compact covered up to 43 member states as of March 2026. (source) [VERIFIED]
  • US Code of Federal Regulations, 21 CFR 1301.13 — The DEA registration application and renewal fee for practitioners is $888 for a three-year registration period. (source) [VERIFIED]
  • American Medical Association Policy Research Perspectives (May 4, 2026), using Medical Liability Monitor data — Medical liability premiums rose for a seventh consecutive year; the share of reported premiums increasing year over year climbed from 13.7% in 2018 to nearly 40% in 2025, the highest since 2005; the reported 2025 manual premium for an internal medicine physician in Miami-Dade County, Florida was $59,736 against $243,988 for ob-gyn and general surgery in the same market. (source) [VERIFIED]
  • Alston & Bird health care advisory on FDA action — FDA declared the shortage of all doses of injectable semaglutide resolved in February 2025; enforcement discretion ran to April 22, 2025 for 503A compounding pharmacies and May 22, 2025 for 503B outsourcing facilities. (source) [VERIFIED]
  • IQVIA (US blog, October 2025) — FDA removed tirzepatide from the shortage list in December 2024 with compounding expected to cease by March 2025; compounded GLP-1 prescribing continued to rise after delisting; more than 80% of compounded prescriptions include supplemental ingredients. (source) [VERIFIED]
  • US FDA — A compounded semaglutide or tirzepatide product may contain the same active ingredient but is not the drug FDA reviewed and approved; FDA does not evaluate specific compounded products for safety, effectiveness, manufacturing quality or consistency; FDA has received hundreds of adverse event reports including dosing-error reports, has warned of fraudulently labelled product naming pharmacies that do not exist, and issued more than 50 warning letters in September 2025. (source) [VERIFIED]
  • Federal Register / US FDA docket notice (June 26, 2026) — FDA proposed on April 30, 2026 to exclude semaglutide, tirzepatide and liraglutide from the 503B bulk drug substances list, finding no clinical need and expressly rejecting affordability and insurance access as constituting clinical need; the comment period was extended with comments due July 30, 2026. (source) [VERIFIED]
  • Novo Nordisk / NovoCare Pharmacy (manufacturer page, checked August 2026) — Wegovy self-pay pricing through NovoCare Pharmacy starts at $149 per month for the 1.5 mg or 4 mg oral doses for new patients; the standard pen starts at $199 per month for the first two months as a limited-time offer; the HD 7.2 mg pen starts at $399 per month after the introductory period; pricing subject to change. (source) [VERIFIED]
  • CNBC — November 6, 2025 White House agreements with Eli Lilly and Novo Nordisk set starting doses at $350 per month via TrumpRx launching January 2026, trending toward $245 per month over two years. (source) [VERIFIED]
  • Federal Register / Federal Trade Commission, 16 CFR Part 465 — The Trade Regulation Rule on the Use of Consumer Reviews and Testimonials was published August 22, 2024 and took effect October 21, 2024; it prohibits fake or false consumer reviews and testimonials, insider reviews and testimonials without clear disclosure of the material connection, and compensation or incentives conditioned on expressing a particular sentiment. (source) [VERIFIED]
  • Practice-management publishers and consultancies (aggregate; no single authoritative survey) — Commonly cited first-year medical practice startup and operating ranges of roughly $70,000–$500,000, with build-out $20,000–$60,000, clinical equipment $15,000–$75,000, IT infrastructure and EHR $10,000–$25,000, and $500–$2,000 per month EHR/technology subscriptions. Widely repeated attribution to MGMA could not be traced. Cost only; no revenue figure accompanies these and none may be derived. [INFERENCE]
  • Atlas Metabolic editorial judgment (reasoned from the above; not a survey finding) — A telehealth-first or hybrid model shifts cost composition rather than reducing a stated total, avoiding build-out and clinical equipment lines while adding multi-state licensure and technology lines; and the items flagged COMMONLY MISSED reflect our own observation of where startup checklists fail, not published research. [INFERENCE]

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