Policies & Compliance

Global Medical Team procures all medical equipment, devices, and supplies exclusively for direct end-use in its own physician-directed operations. These operations include clinical patient care, medical training and simulation, and scientific device validation conducted under institutional or IRB-approved research protocols. GMT does not maintain wholesale, distribution, or dealer operations of any kind.

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GMT does not engage in the resale, redistribution, brokering, consignment, or unauthorized transfer of medical products to any third party, whether domestic or international. All procurement is authorized at the physician level by GMT's Medical Director, and all items remain under the direct custody and control of the organization from the point of receipt through final disposition. No item leaves GMT's custody without a documented authorization and a recorded chain-of-custody event.

GMT maintains a formal internal procurement and inventory control program that governs vendor onboarding, purchase authorization, receiving and inspection, storage, deployment tracking, and end-of-life disposition. This program is subject to periodic internal audit by the Medical Director. GMT's procurement controls are designed to meet or exceed the compliance expectations of major medical equipment manufacturers and authorized distributors.

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GMT considers proactive end-use accountability a baseline element of responsible medical procurement. Vendor compliance teams with questions about GMT's procurement posture are encouraged to contact the Medical Director directly; GMT is committed to responding to all compliance inquiries within five business days.

All clinical operations conducted by or on behalf of Global Medical Team are performed under the direct authority of a physician who holds an active, unrestricted medical license in the applicable jurisdiction. GMT does not delegate clinical decision-making to unlicensed personnel, and all patient care activities occur within a clearly defined scope of practice governed by applicable state and federal law.

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GMT's Medical Director maintains all licensure, board certifications, and registrations required to support the organization's clinical scope of practice. This includes state medical licensure; board certification in a relevant medical specialty; Drug Enforcement Administration (DEA) registration for the prescribing, procurement, and management of controlled substances; and National Provider Identifier (NPI) registration.

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Where GMT operations require non-physician clinical personnel to perform advanced medical interventions, those personnel operate under physician-issued Standing Medical Orders (SMOs) that define the specific procedures authorized, the clinical conditions under which they may be performed, the required training and credentialing prerequisites, and the documentation and reporting obligations for each intervention. SMOs are reviewed and reissued by the Medical Director on a recurring basis and are tailored to the specific operational environment and mission profile. GMT does not issue blanket authorizations; every SMO is scoped to a defined clinical context.

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GMT's prescriptive authority structure ensures that all medication administration, controlled substance management, and clinical intervention occurring under the GMT umbrella can be traced to a named, licensed physician operating within the lawful scope of their practice. This chain of authority is maintained regardless of geographic location or operational tempo.

Global Medical Team procures and utilizes FDA-regulated medical devices in its clinical, training, and research operations. GMT operates as a clinical end-user of these devices, not as a manufacturer, reprocessor, distributor, or dealer. GMT does not modify, relabel, or repackage any FDA-regulated device, and does not market or promote medical devices to any third party.

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All Class II and Class III medical devices procured by GMT are sourced through authorized manufacturers, authorized distributors, or established medical supply channels. GMT does not procure regulated devices through secondary markets, liquidation sales, or unverified sources. Prior to deployment, all devices are inspected to confirm that labeling, packaging, and condition are consistent with manufacturer specifications.

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GMT complies with all applicable FDA requirements for device end-users, including adherence to manufacturer instructions for use (IFU), operator training and competency requirements, and adverse event and malfunction reporting obligations under the Medical Device Reporting (MDR) framework (21 CFR Part 803). Any device-related adverse event, malfunction, or near-miss occurring during GMT operations is documented and reported through appropriate channels within the timeframes prescribed by regulation.

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Where GMT conducts scientific validation, bench-testing, or field-evaluation of medical devices under research protocols, those activities are performed under physician oversight and in accordance with applicable FDA guidance on investigational use. Devices undergoing research evaluation are tracked separately from clinical inventory and are clearly designated as investigational when their regulatory status requires it.

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GMT maintains records of all regulated devices in its inventory, including manufacturer identity, model and serial number, date of acquisition, source, and deployment history. These records support both GMT's internal inventory control program and any reporting obligations that may arise under FDA post-market surveillance requirements.

Global Medical Team procures, stores, and utilizes controlled substances exclusively under the authority of a DEA-registered physician operating within the lawful scope of their medical practice. GMT does not distribute, dispense to the general public, or otherwise transfer controlled substances outside of its own physician-directed clinical operations.

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GMT's controlled substance activities are governed by the Controlled Substances Act (21 USC §§ 801–904) and its implementing regulations (21 CFR Parts 1301–1321), as well as applicable state pharmacy and medical board requirements in each jurisdiction where GMT conducts operations. GMT maintains an active DEA registration appropriate to the schedules and activities required by its operational scope, and will obtain additional registrations as necessary if that scope expands.

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All controlled substance procurement is authorized exclusively by the Medical Director. GMT procures scheduled medications only through DEA-registered manufacturers, distributors, or pharmacies, and does not obtain controlled substances through secondary markets, peer-to-peer transfers, or unverified sources. Each procurement transaction is documented with the date, source, quantity, schedule, and intended use category.

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GMT maintains a controlled substance inventory log that records all receipts, administrations, wastage events, and dispositions. Inventory counts are reconciled on a periodic basis as determined by operational tempo, and no less than annually. All wastage is witnessed, documented, and countersigned. Discrepancies between expected and actual inventory are investigated by the Medical Director and documented regardless of magnitude.

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Disposition of expired, unused, or otherwise unneeded controlled substances is conducted in accordance with DEA reverse distribution and disposal requirements (21 CFR Part 1317). GMT does not dispose of controlled substances through unauthorized means, and maintains records of all disposition events including the method, date, quantities, and any reverse distributor documentation.

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Physical security of controlled substances meets or exceeds DEA requirements for the applicable registration type, including storage in a securely locked, substantially constructed cabinet or safe with access restricted to the Medical Director and specifically authorized personnel.

Global Medical Team collects, maintains, and safeguards protected health information (PHI) in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the HITECH Act, and their implementing regulations (45 CFR Parts 160 and 164). GMT treats the privacy and security of patient information as a foundational obligation, not an administrative afterthought.

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GMT limits the collection of PHI to the minimum necessary to support the clinical, operational, or administrative purpose for which it is gathered. PHI is not disclosed to any third party except as required for treatment, payment, or health care operations; as authorized by the patient in writing; or as required by law. GMT does not sell PHI, does not use PHI for marketing purposes, and does not share PHI with any entity outside of these narrowly defined circumstances.

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GMT implements administrative, physical, and technical safeguards to protect PHI against unauthorized access, use, disclosure, alteration, or destruction. These safeguards include access controls limiting PHI availability to authorized personnel on a need-to-know basis, encryption of electronic PHI (ePHI) at rest and in transit, secure storage of paper records in locked facilities with restricted access, workforce training on privacy and security obligations, and defined procedures for the secure disposal of PHI in both electronic and physical formats.

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Where GMT engages third-party service providers who may access, transmit, or store PHI on GMT's behalf, those relationships are governed by Business Associate Agreements (BAAs) executed prior to any PHI exchange. GMT does not permit business associates to use or disclose PHI beyond the scope defined in the applicable BAA.

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In the event of a breach of unsecured PHI, GMT will comply with all applicable breach notification requirements under 45 CFR Part 164, Subpart D, including notification to affected individuals, the Department of Health and Human Services, and where required, media outlets, within the timeframes prescribed by regulation. All suspected breaches are investigated by the Medical Director and documented regardless of whether they ultimately meet the regulatory threshold for notification.

Patients and clients may request access to their PHI, request amendments to their records, or request an accounting of disclosures by contacting GMT's Medical Director. GMT will respond to all such requests within the timeframes required by HIPAA.

Global Medical Team maintains professional liability and general liability insurance coverage appropriate to the scope and nature of its clinical, consulting, and operational activities. Coverage is procured through carriers rated A- or better by A.M. Best, and policy limits are maintained at levels consistent with industry standards for physician-led medical service organizations.

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GMT's insurance program includes professional liability (medical malpractice) coverage for all clinical services performed by or under the direction of GMT physicians, commercial general liability coverage for GMT's business operations, premises, and equipment, and products and completed operations coverage where applicable to GMT's device validation and research activities.