Skip to content
Physicians 01 Compliance

Integrity is a regulatory posture, not a slogan.

BORN distinguishes what is validated from what is observed, and operates within every regulatory boundary. Here is exactly where the facility and the product stand.

01 Regulatory Position

Facility: registered 361 HCT/P lab

Operates under Section 361 of the Public Health Service Act, following 21 CFR 1271 standards for recovery, storage, screening, processing, and labeling.

Product: outside HCT/P classification

Per 21 C.F.R. § 1271.3(d)(3), Cell Factors are not HCT/Ps — neither a 351 nor a 361 product — confirmed by former FDA, DOJ, and OIG advisors.

Disease Awareness Communications

Disease-state education and product-specific materials are kept separate, so communications do not constitute labeling or advertising under the FDCA.

Drug-testing status

Not prohibited under WADA, IOC, the NFLPA CBA, or Drug Free Sport International. Patients have passed testing at the NFL, NBA, MLB, NCAA, and U.S. government levels.

02 Compliance Advisors

Counsel from former regulators.

Alan Minsk
Partner
Former FDA
Robert Durkin
Partner
Former DOJ
David Blank
Partner
Former OIG
Reversing the Irreversible

Practice at the frontier — within every boundary.