A written, on-the-record review — every quarter, every location, every provider — that confirms the operation still matches what its contracts, protocols, and state rules require. If a state board, malpractice carrier, or diligence team asks, this is the paper trail.
Attestation 1 · Location
Completed by each location's owner of record. Every line answered YES, NO, or N/A — every NO explained. Citations are for education, not legal advice.
Section 1
Regulatory basis: State corporate practice of medicine doctrine; PC/MSO and fee-splitting statutes.
Section 2
Regulatory basis: State medical and nursing practice acts; supervision, delegation, and provider-patient relationship rules.
Section 3
Regulatory basis: Applicable standard of care; scope-of-practice law; adverse-event reporting.
Section 4
Regulatory basis: State licensing boards; scope, supervision, and collaborative-practice requirements; malpractice.
Section 5
Regulatory basis: Informed-consent doctrine; state medical record content and retention rules.
Section 6
Regulatory basis: HIPAA 45 C.F.R. Parts 160 & 164; state privacy laws such as California CMIA.
Section 7
Regulatory basis: State pharmacy boards; Controlled Substances Act, 21 U.S.C. 801 et seq.; USP <797>/<800>; FDCA §503A/503B.
Attestation 2 · Provider
Completed each quarter by every clinical provider. Personal accountability for licensure, protocol adherence, Medical Director engagement, safety, and conduct.
Section 1
Section 2
Section 3
Section 4
Section 5
How the cycle runs
Step 1
Send the Location Attestation to each site's leadership and the Individual Provider Attestation to every clinician at the start of the quarter.
Step 2
Answer YES, NO, or N/A on every item. Every NO requires a written explanation in the section's notes box.
Step 3
Owner of record signs the Location Attestation; each provider signs their own. Submit via secure upload.
Step 4
Compliance lead reviews within 10 business days, opens corrective-action items with owners and due dates, and issues a findings memo.
Step 5
Prior-quarter corrective actions are re-verified in the next attestation cycle before new items are accepted.
FAQ
A quarterly compliance attestation program is a documented, cadenced self-review process where each clinic location and every clinical provider confirms — in writing, on the record — that the operation is still running the way its contracts, protocols, and state rules require. Camino's program has two parts: a Location Attestation completed by leadership and an Individual Provider Attestation completed by every clinician.
Regulators, malpractice carriers, and diligence teams look for a rhythm — evidence that oversight is continuous, not a one-time binder. Quarterly cadence surfaces license lapses, protocol drift, missed Medical Director engagement, and adverse-event patterns while they're still cheap to fix, and it produces a defensible paper trail across a rolling 12 months.
Seven areas: (1) Entity Structure & Corporate Compliance, (2) Clinical Leadership & Oversight, (3) Clinical Protocols & Standard of Care, (4) Staffing, Licensure & Scope of Practice, (5) Patient Consent & Documentation, (6) Privacy & Security (HIPAA / state), and (7) Medications & Supplies including controlled-substance handling.
Five areas each clinician confirms personally: (1) Licensure & Credentialing, (2) Clinical Practice & Standard of Care, (3) Medical Director / Supervision Engagement, (4) Patient Safety, Consent & Documentation, and (5) Privacy, Conduct & Operations.
Camino reviews each quarter's submissions, tracks 'No' answers and 'N/A' items, opens corrective-action items with owners and due dates, and produces a short findings memo. The point is to be the friendly reviewer — before a state board, payment processor, biller, or plaintiff attorney becomes the not-so-friendly one.
No. The programs and their citations (state medical/nursing practice acts, HIPAA 45 C.F.R. Parts 160 & 164, Controlled Substances Act 21 U.S.C. 801 et seq., USP <797>/<800>, FDCA §503A/503B, state privacy laws such as California CMIA) are educational only. Specific requirements vary by state, specialty, and practice model — confirm with counsel.
The Location Attestation's first section directly tests whether the PC/MSO structure required by the state's Corporate Practice of Medicine doctrine is still intact — no unreported ownership changes, MSA on file, fair-market-value management fees, and clinical control resting with the licensed practice.
Related: Our compliance philosophy · CPOM by state · Board submission by state
We'll issue the location and provider attestations, review the results, and open the corrective actions — so the next set of eyes on your operation is ours, not a regulator's.