A brochure is written to sell. A consent form records what you agreed to. The plan is the one document written for you, and it is where a clinic shows its thinking, or shows that it hasn't done any.
What follows applies to any clinic in regenerative medicine offering elective therapies, in any state. It is general information, not medical or legal advice, and the best person to read a plan with is your own physician. If a clinic won't put its plan in writing for you to take home, that tells you most of what you needed to know.
The nine parts
1. What is proposed, and why
The plan should name each product and service, who provides it, and why it was chosen for you. “Why” should point to your history and your goals, not to the product's reputation. If the paragraph would read the same with someone else's name at the top, it isn't a plan yet.
2. FDA status, in plain words
For each item, one sentence saying whether the FDA has approved it for the use proposed. The FDA publishes a list of the cellular and gene therapy products it has approved, so for a cellular product you can check the answer yourself.
Watch for stand-ins. “FDA-registered” and “meets FDA guidelines” are not approval: the FDA says that a firm registering with the agency and listing its product does not mean the product is legally marketed. Compounded medications are not FDA-approved either. The FDA does not review them for safety, effectiveness or quality before they reach patients. What “not FDA-approved” actually means goes further.
3. The alternatives, including doing nothing
Look for the other recognized options: care through your own physician, other elective choices, and leaving things as they are. Each deserves a fair sentence, including the ones this clinic doesn't sell. A plan with a single option in it is an order form.
4. The recognized risks
Risks should be named, not summarized. Look for the serious ones as well as the common ones, what is watched for on the day, and what happens if one occurs. “Minimal risk” with nothing listed underneath is not a risk section.
5. What is not yet known
This is the part to look for hardest, because it tells you the most about the people who wrote the rest. Where a therapy is not FDA-approved, open questions come with it. The plan should say what is known, where the evidence stops, and what nobody can tell you yet. If the words “we don't know” appear nowhere in the document, ask where they went.
6. Who is responsible for what
Names and roles. Who reviewed your history and stands behind the plan. Who is with you on the day. Who you call afterwards, and how. Where a prescription is involved, who prescribes and which pharmacy fills it. The plan should also say what is yours: telling your own physician, following the aftercare instructions, and reporting anything that worries you.
7. The timeline and the follow-up
Dates, not adjectives. What happens ahead of the appointment, on the day and in the weeks after. When someone checks on you, and who starts that conversation. When you sit down to review. A plan that ends on the day of the appointment is a receipt.
8. The total cost, in writing
One total, with what it includes and what it doesn't. Follow-up visits, prescriptions, repeat appointments and travel are the places to check for a second bill. You should have the figure before anything is scheduled, along with what happens to money already paid if you stop.
9. How to pause or say no
Look for the way out: how to postpone, how to cancel, who to tell and what it costs. There should be no deadline on the decision. If the price or the tone changes because you asked for a week, you have learned something about the clinic, and it cost you nothing.
- No written plan, or one you can't take home.
- FDA status left out, or dressed up as “FDA-registered” or “FDA-compliant.”
- The word “safe,” a promised outcome, or a guarantee of any kind.
- No alternatives, or none the clinic doesn't sell.
- A total that isn't a total.
- A deadline.
Where the consent form fits
The plan is there so you can decide. The consent form records that you did. The two overlap, and in Utah part of that overlap is written into law.
Utah Code 58-1-512 lets a health care provider whose scope of practice includes stem cell therapy perform a stem cell therapy that is not FDA-approved, but only after giving the patient a specific written notice and obtaining a signed consent form. (The statute exempts some providers.) The form has to be written in language the patient could reasonably be expected to understand. Among other things, it has to state the FDA approval status, the recognized alternatives, and the recognized serious possible risks of what is proposed, of those alternatives, and of doing nothing.
Know the limits of that rule. It covers stem cell therapy as the statute defines it, so it does not reach every elective program a clinic offers. It is a state licensing rule about disclosure and consent: it does not make any therapy FDA-approved, and it does not change federal law. More on the Utah rule.
And a signature is no substitute for time to read. Ask for the consent form ahead of the day, and read it at home beside the plan. If the two disagree, ask why.
Before you sign anything
Read the plan at home, with a pen. Mark every sentence you don't understand and every part that is missing, then send the list back. How a clinic answers that list is the best preview you will get of how you'll be looked after later.
Then show it to your own physician. Utah's notice encourages you to talk with your primary care provider first, and that is sound advice for any plan from any clinic.
At Nuvira, the plan is written in plain language after your clinician's review, covers options, risks, evidence and cost, and is yours to keep and read before you decide. Our therapies are elective and not FDA-approved, candidacy is decided at consultation, and no outcome is promised.
Sources
- Utah Code 58-1-512, “Stem cell disclosure”, Utah State Legislature, version in force since May 6, 2026
- Important Patient and Consumer Information About Regenerative Medicine Therapies, U.S. Food and Drug Administration, content current as of April 8, 2024
- Approved Cellular and Gene Therapy Products, U.S. Food and Drug Administration, content current as of September 17, 2026
- Human Drug Compounding Laws, U.S. Food and Drug Administration, content current as of December 17, 2024