SOLVO MEDLINK OPERATIONAL POLICIES

Document ID: GOV-2026-001

Version: 1.0

Last Updated: February 24, 2026

1. Policy on Clinical Autonomy & Non-Interference

Applicability: All Company Personnel (Employees, Contractors, Interns, and Officers).

  • Objective: To strictly adhere to the Corporate Practice of Medicine (CPOM) doctrines and California SB 351.

  • Non-Interference: The Company provides administrative, technological, and infrastructure support only. No Company personnel shall interfere with, suggest, or override a Member Clinician’s professional medical judgment.

  • Professional Discretion: Member Clinicians maintain sole authority over patient care, including but not limited to: diagnosis, treatment plans, medical necessity determinations, and duration of patient encounters.

  • Independent Practice: All clinicians operating via the Solvo MedLink platform are independent practitioners. Company personnel shall not establish "clinical quotas" or performance metrics based on medical outcomes or patient volume.

2. Financial Integrity & Fair Market Value (FMV) Policy

Applicability: Accounting, Finance, and Executive Leadership.

  • Fixed-Fee Architecture: All revenue collected by the Company from Member Clinicians must be based on a Fixed Monthly or Annual Membership Fee. * Anti-Fee-Splitting: The Company shall not accept any percentage-based "cut" or "commission" from professional medical fees. To do so is a violation of Business & Professions Code 650 and is grounds for immediate termination.

  • Separation of Funds: Professional fees for medical services are settled directly to the Member Clinician’s bank account via authorized payment processors. The Company never takes possession of clinical funds.

  • Referral Prohibitions: Company personnel are strictly prohibited from paying or receiving "kickbacks" or referral fees for the recruitment of patients or clinicians.

3. Data Governance & HIPAA Role-Based Access (RBAC)

Applicability: All Personnel with access to Company Systems.

  • Access Tiers: System access is granted based on the "Principle of Least Privilege":

    • Administrative/Accounting Roles: Access is restricted to financial metadata, membership status, and credentialing verification. No access to Protected Health Information (PHI) or clinical notes.

    • Management Roles: Access to platform analytics and high-level member data. No access to PHI.

  • Encryption & Security: All Company-issued or authorized devices must utilize AES-256 bit encryption. Two-Factor Authentication (2FA) is mandatory for all platform access.

  • Data Breach Protocol: Any suspected unauthorized access to patient or clinician data must be reported to the Privacy Officer within 24 hours.

4. Network Integrity & Vetting Standards

Applicability: Operations and Credentialing Department.

  • Primary Source Verification (PSV): Prior to activation on the platform, all clinicians must undergo PSV via the California Breeze system or appropriate state licensing board.

  • The "Prescriber Gate" Requirement: For Mid-Level Practitioners (NPs/PAs), an active and signed Practice Agreement or Delegation Protocol must be verified and stored in the Company’s secure vault.

  • OIG/SAM Sanctions: No individual appearing on the Office of Inspector General (OIG) exclusion list shall be permitted to join the Solvo MedLink network.

5. Workplace Standards & Ethical Conduct

Applicability: All Workforce Members.

  • Transparency: Solvo MedLink maintains a culture of pay transparency and open communication regarding Company goals and infrastructure changes.

  • Intellectual Property (IP): All personnel acknowledge that the "Prescriber Gate," the "Midnight Ink" design aesthetic, and Company trade secrets are the sole property of Solvo MedLink LLC.

  • Reporting: All personnel have a duty to report any observed violation of these policies to the CEO without fear of retaliation.