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Trust · Attestations

Compliant today. Audited soon.

This page is the live registry of every control program that governs Conceptual Health® — the standard, the scope, who owns it inside the company, where it stands today, and what document a regulator or enterprise procurement team can pull. We honestly disclose the difference between "architected and self-attested" and "third-party-signed letter in hand." Eleven controls are in scope now; six more are on the roadmap with target windows below.

Phase 1 honesty banner

10 self-attested · 0 third-party signed · 11 Phase 2 pending.

"Self-attested" means we have architected, implemented, and internally validated the control program against the published standard. It does not mean an independent auditor has signed a letter. The path to a signed letter requires (a) the audit engagement and (b) the observation window. We have published target dates below and will move each row from "Self-attested" → "Engagement" → "Letter issued" with the date stamp and auditor name as it happens.

In scope now

The eleven control programs running today.

Security · Privacy

SOC 2 Type II

Trust Services Criteria 2017 — Security, Availability, Confidentiality, Privacy, Processing Integrity. Twelve-month audit period once the engagement begins. Status: self-attested · engagement pending.

Healthcare

HITRUST CSF r2

156 controls across 14 categories. 24-month certification validity. Status: self-attested · engagement pending.

Cryptography

FIPS 140-3

AES-256-GCM and ChaCha20-Poly1305 (data at rest). TLS 1.3 with X25519 (data in transit). Ed25519 signing for chain operations. SHA-256 and SHA-3-256 hashing. Status: compliant · vendor modules validated.

Healthcare · Federal

HIPAA — 45 CFR 160/164

Privacy Rule, Security Rule, Breach Notification Rule. BAA template at /legal/baa-template/. Notice of Privacy Practices at /legal/hipaa/. Status: compliant · operational.

Research · FDA

21 CFR Part 11

Electronic-records validation for clinical research data, signed audit trails, controlled-system-of-record posture. Status: self-attested · IRB validation in progress.

Controlled substances

DEA EPCS — 21 CFR 1300

Electronic prescribing of controlled substances: two-factor identity proofing for clinicians, two-token signing for each prescription. Status: self-attested · third-party identity-proof partner engaged.

Financial · Federal

FinCEN MSB Registration

31 CFR 1010 — KYC, AML, OFAC screening. State Money Transmitter License (MTL) matrix in progress; NMLS lookup will be published per state as licenses issue. Status: federal registration filed · state matrix in progress.

Financial · Card

PCI DSS v4.0 — SAQ-D

Cardholder-data environment scope. QSA engagement triggered with the first card-present clinic. Status: scoped · engagement pending.

Security · Operations

Annual penetration test

White-box plus black-box. Network, application, AI prompt-injection, BAA-as-code, edge-node verification. Findings → fixes → re-test → public summary in the Transparency Report. Status: annual cadence established.

Accessibility

WCAG 2.2 Level AA

Section 508 conformance, skip-link on every page, prefers-reduced-motion honored, 44×44 minimum touch targets, AAA where feasible. Tested with NVDA, JAWS, VoiceOver, TalkBack, Dragon. Statement at /legal/accessibility/. Chain-stamped scorecard at /proof/accessibility.html. Status: compliant · per-release validated.

Money-services

State Money Transmitter Licenses

Per-state MTL matrix tracking application status. License numbers will appear here as states issue. Status: matrix in progress · NMLS lookup pending issuance.

Roadmap — Phase 2 and beyond

What we'll be working toward, with dates.

Standard Scope Target
FedRAMP Moderate Federal government-customer authorization Phase 2 + 18 months
ISO 27001 + 27701 Information security + privacy management Phase 2 + 12 months
FDA SaMD Pre-cert Software-as-a-Medical-Device pathway for clinical features Rolling · post Phase 2
NCQA HEDIS Healthcare Effectiveness Data and Information Set reporting Phase 2 + 12 months
HITRUST AI Assurance Clinical-AI controls — model governance, override audit, drift detection Post Phase 2
SOC 3 Public summary report (post SOC 2 Type II) After SOC 2 letter

Document access

Regulators and enterprise procurement: come in.

Audit letters, control narratives, evidence libraries, and BAA-signed copies are available behind the NDA-gated regulator portal. On-chain attestations and governance log: chain.conceptualhealth.com/governance-log.html.

Anything inaccurate, ambiguous, or missing on this page? Write compliance@conceptualhealth.com — we'd rather correct the page today than relitigate the claim later.