Medication-access infrastructure for ACNU programs.

ClearGate helps pharmaceutical sponsors connect program design, access decisions, and pharmacy verification. Gatehouse manages the program. Passage verifies authorization at checkout.

Initial focusAdditional Condition for Nonprescription Use (ACNU)
For sponsors and partnersFrom program design to pharmacy checkout
Current stageWorking demonstration · seeking design partners
Explore a Gatehouse release example Illustrative workspace · fictional data

Connect the whole medication-access program.

ACNU means Additional Condition for Nonprescription Use. Under the FDA framework, a consumer must complete an additional condition to obtain and appropriately use a specific nonprescription drug.

ClearGate is designed to support technology-based ACNU programs: turn sponsor-defined criteria into versioned questions and rules, validate changes, verify authorization, and retain the records needed to review what happened.

Designed for sponsor-specific implementation. The demonstration is not a commercially qualified deployment. Each implementation requires validation, security qualification, operating procedures, partner certification, and service agreements.

Product-specific
Each program has its own questions, rules, consumer messages, authorization policies, and release history.
Deterministic
Identical inputs under the same approved version produce the same result. Generative AI does not make the qualification decision.
Traceable
Study records, access decisions, transaction events, safety signals, and corrective actions remain linked to the program version.

Gatehouse and Passage. Connected, with clear roles.

Gatehouse controls how the program is defined and run. Passage connects its approved outcomes to pharmacy and ecommerce verification. A signed handoff links the two.

Program platformGatehouse

Gatehouse: design and operate your program.

Configure questionnaires and rules, prepare studies, validate releases, and review access decisions. Gatehouse records the program version behind each decision and signs the handoff to Passage.

  • Portfolio and program configuration
  • Questionnaire and rule editing
  • Study deployments and scenarios
  • Validation and release approvals
  • Runtime and signed authorization
  • Safety monitoring, corrective actions, evidence
Approved releaseDeterministic decisionSigned, minimal handoffChannel verification
Authorization networkPassage

Passage: verify authorization at checkout.

Passage checks an approved upstream result, issues or verifies an authorization, and applies transaction policies. Pharmacy and ecommerce partners receive the information needed to verify access without receiving questionnaire answers.

  • Shared product registry
  • Signed assertion and authorization validation
  • Verify, redeem, retry, and reverse
  • Point-of-sale and ecommerce integrations
  • Minimal data in partner responses
  • Append-only transaction ledger

Built to work with other systems. Passage can accept an approved result from Gatehouse or another approved upstream system. An authorization is not a prescription; clinical and prescribing responsibilities remain with the appropriate parties.

Verify access in pharmacy and ecommerce workflows.

The Passage demonstration shows authorization checks, single-use redemption, safe retries, reversals, and a record of each transaction. The pharmacy and product below are fictional.

Passage
Example service status
BRIGHTWELL PHARMACY GROUP · BWPG-001Authorization verification

Product detected at checkout · Location AVL-014

Partner authenticated
Brightwell POS

Reference pharmacy adapter

Product detectedVirelixa 5 mgNDC 00000-0000-00 · Qty 1
Access required
Authorization presentedcgp1.eyJraWQiOiJwYXNzYWdlLWtleS0wMSI…
Authorization validSingle-use · product and location policy matched
VALID
Recent network activityImmutable transaction lineage
TimeEventActorAuthorizationResult
10:32:08VERIFYBWPG-001 / AVL-014AUTH-VRX-829401VALID
10:31:44ISSUEHCT / GatehouseAUTH-VRX-829401ISSUED
10:28:19REVERSEBWPG-001 / AVL-006AUTH-VRX-735280REVERSED
Synthetic data · fictional product, pharmacy, identity, and transaction records.

Trace each decision to its program version.

Review which rules were used, which release was approved, and how an authorization reached the retailer. The example below shows how assessment and transaction records stay connected.

Decision and transaction lineageAUTH-VRX-829401
  1. 01
    AssessmentASM-9B82F4C1
    Completed against release 1.1.0
  2. 02
    Deterministic decisionDEC-382910
    Reason codes and rule version retained
  3. 03
    Signed authorizationAUTH-VRX-829401
    Minimal permitted metadata only
  4. 04
    Retail verificationTXN-70F18A
    Partner, location, policy, and state linked

Synthetic demonstration data. No real drug, consumer, clinical criteria, identity, or transaction is represented.

From program design to ongoing oversight.

Explore the workflows demonstrated across Gatehouse and Passage.

Feasibility

Portfolio and program definition

Define candidate products, sponsor objectives, program owners, system boundaries, and release versions.

  • Portfolio
  • Program ownership
  • Tenant isolation
Design

Questionnaires and deterministic rules

Approved questions, criteria, reason codes, outcome messages, rule tests, and change history stay versioned and traceable.

  • Designer
  • Rules
  • Validation
Research

Study deployment and evidence

Study-specific configuration supports sponsor and research workflows while preserving the relationship to the future operating model.

  • Study versions
  • Scenarios
  • Evidence export
Operate

Runtime, decisions, and authorization

Consumers receive only the approved experience while decisions remain deterministic, version-bound, and ready for minimal signed handoff.

  • Defined outcomes
  • Fail-closed
  • Authorization policy
Integrate

Pharmacy, ecommerce, and channel adapters

Verification and transaction enforcement stay separate from clinical logic through scoped, versioned partner contracts.

  • POS
  • Ecommerce
  • Verify / redeem / reverse
Control

Safety monitoring, corrective actions, and audit

Signals become investigations, affected records can be identified, corrective action stays linked, and released history cannot be silently rewritten.

  • Vigilance
  • Corrective and preventive action (CAPA)
  • Evidence lineage

Demonstration scope: the screens use fictional data. Commercial use requires sponsor-specific validation, security qualification, partner certification, operating procedures, and service agreements.

Keep control when something goes wrong.

Trace an issue to affected decisions and transactions, investigate its cause, and link corrective action to a controlled release. The example below illustrates that workflow.

Open investigation
CASE-ACNU-0004Severity 2 · Synthetic demo
SignalMalformed lab units14:02
ImpactAssessments identified14:06
Root causeAdapter validation gap15:14
CAPACAPA-0012 opened15:37
Controlled changeCorrected release validated18:22
Fail-closed behavior

If a reliable decision or valid authorization is unavailable, access is not permitted.

Immutable released history

Released configuration and ledger events cannot be silently rewritten.

Separation of duties

Authors, approvers, operators, source systems, and retailers remain distinct.

Data minimization

Each downstream actor receives only what its approved transaction requires.

Build the next stage with ClearGate.

We are seeking pharmaceutical sponsors, research organizations, pharmacy technology teams, and advisors to help shape program requirements and plan pilot implementations.

Sponsor

Pharmaceutical and consumer-health companies

Discuss a candidate product, an active or planned Rx-to-nonprescription program, or a medication-access workflow that needs supporting infrastructure.

  • Candidate-program feasibility
  • Design engagement
  • Sponsor-led pilot planning
Research

Contract research and consumer-behavior research organizations

Partners equipped to design or operate label comprehension, self-selection, actual-use, human-factors, or adjacent research against a controlled program configuration.

  • Study workflow design
  • Research-site operations
  • Evidence and data handoff
Channel

Pharmacy, retailer, and ecommerce technology teams

Partners willing to shape how product detection, verification, redemption, reversal, exception handling, and channel accountability should work in practice.

  • Reference adapter collaboration
  • POS or ecommerce pilot
  • Partner certification model
Advisory

Regulatory, quality, vigilance, and industry operators

Experienced operators who can pressure-test responsibility boundaries, validation strategy, failure procedures, quality systems, and sponsor buying requirements.

  • Regulatory and quality review
  • Vigilance operating model
  • Strategic or technical advisory

A practical path to a pilot.

We can begin before every downstream vendor or implementation detail is selected.

  1. 1Choose a programCandidate asset, study, pathway, or channel pilot
  2. 2Define the boundaryOwners, criteria, systems, evidence, and success measures
  3. 3Configure the modelSynthetic workflow, rules, authorization, and integrations
  4. 4Plan the evidenceValidation, research, pilot, and operating readiness

Clear responsibilities at every stage.

Sponsors retain clinical criteria, regulatory strategy, and product obligations. ClearGate provides the software that implements program rules and records its operation.

Pharmaceutical sponsor

Owns the product and program.

  • Clinical criteria and regulatory strategy
  • Approved consumer content
  • Drug safety and sponsor obligations
  • Program oversight and accountability
ClearGate

Provides the controlled operating layer.

  • Configuration and deterministic execution
  • Validation evidence and release controls
  • Authorization exchange and integration
  • Monitoring, incidents, and traceability
Licensed clinician · future pathways

Retains medical judgment.

  • Clinical evaluation where required
  • Prescribing authority
  • Clinician-patient relationship
  • Professional and jurisdictional obligations
Retail or research partner

Performs its approved channel role.

  • Transaction or study operations
  • Authorization enforcement where applicable
  • Partner-specific consumer obligations
  • Evidence and exception handling

Questions about ClearGate and ACNU.

Understand the framework, the products, and what comes next.

What is an ACNU program?

An Additional Condition for Nonprescription Use is an extra step a consumer must complete to obtain and appropriately use a particular nonprescription drug when labeling alone is insufficient. A technology-based assessment may support that condition. Requirements and FDA approval are specific to the drug product.

Read the FDA’s ACNU framework.

How do Gatehouse and Passage work together?

Gatehouse manages program configuration, validation, releases, and access decisions. Passage verifies the signed upstream result and manages authorization checks and transaction records for pharmacy and ecommerce partners.

Is ClearGate ready for commercial use?

ClearGate is currently a working enterprise demonstration using fictional data. A commercial implementation requires sponsor-specific validation, security qualification, operating procedures, partner certification, and service agreements. We are seeking design and pilot partners.

Does ClearGate make clinical or prescribing decisions?

Gatehouse applies sponsor-defined rules consistently; generative AI does not decide qualification. Sponsors retain responsibility for clinical criteria and regulatory strategy. Clinician-mediated prescription workflows are a potential future extension, in which licensed clinicians would retain medical judgment and prescribing authority.

Discuss your medication-access program.

Tell us about your product, program stage, or integration needs. We can walk through Gatehouse and Passage and discuss the requirements for a design engagement or pilot.

Good first attendees
Commercial, regulatory, clinical, quality, research, and technical owners
Useful starting material
Program hypothesis, target channel, open risks, and timing
Current priority
Design sponsors, research collaborators, pilot channels, and advisors

Email the team: contact@cleargateaccess.com