Cerebral

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Cerebral is an online subscription-based mental healthcare provider. Cerebral functions via "telehealth" to provide online therapy, diagnosis assistance, and medication prescription to over 200,000 clients . Cerebral lies within multiple digital mental health startups, including "Done", "Hims/Hers", and "Betterhelp". Co-founded by Kyle Robertson (disinvolved) and Dr. Ho Anh in 2020, Cerebral is currently headquartered in San Francisco, California with a valuation of $4.8B .

Cerebral is well known for its social media marketing via popular websites such as "Facebook" and "TikTok". Cerebral's advertising history has been largely focused on the diagnosis and assistance of ADHD. The company currently faces federal investigation for the over-prescription of stimulant medication and inadequate diagnostic practices.

Services

Cerebral cites itself as being able to assist subscribers struggling with: “anxiety, depression, insomnia, postpartum depression, menopausal depression, ADHD (in certain states), trauma and PTSD, bipolar disorder (in certain states), alcohol dependence (in certain states)” in addition to “relationship issues and divorce, stress management, anger management, LGBTQI+, grief and loss, traumatic life events, confidence and self-esteem, phobias, coping with illnesses” for patients 18 and older .

Cerebral’s prescribers are licensed to provide medication services in all 50 states plus Washington, D.C., with a combination of therapy and prescribed medication services available in 30 states

Cerebral Perscription

Subscription Plans

Cerebral offers two subscription plans. Subscribers are required to choose a subscription plan, complete an evaluation, and attend weekly therapy sessions .

Therapy

Cerebral offers a therapy-only subscription plan for $259 monthly. Clients are able to choose a licensed therapist and participate in weekly video or phone appointments.

Medication + Therapy

Cerebral offers a medication and therapy subscription plan for $325 monthly. Clients are able to choose a licensed therapist, participate in weekly video or phone appointments, receive an evaluation and diagnosis from a medical prescriber, and participate in routine check-ins with the assigned medical prescriber. Medication costs are determined and billed separately from the subscription plan cost.

Website and App

Cerebral’s online interface allows clients to schedule appointments, send and read messages, access self-care resources, and view their progress measurements. Cerebral currently operates as www.cerebral.com.

Cerebral also offers clients access to its corresponding app via "Apple App Store" or Google Play Store.

Cerebral IOS App

Partners

Funding

Cerebral has received over $460 million in funding since its launch . Softbank, a Japanese Internet service provider conglomerate, is Cerebral’s main investor through the organization's Vision Fund, an investment fund focusing on non-traditional technologies.

Truepill

Truepill is Cerebral’s pharmacy partner. TruePill provides pharmacy deliveries from businesses to customers by utilizing digital health for large-scale prescription provision. Truepill operates primarily through telehealthcare with companies such as Cerebral, GoodRx, American Airlines, and Hims.

The company was founded in 2016 by Sid Viswanthan and Umar Afrid, and is headquartered in San Mateo, California. Truepill is accredited by the National Association of Boards of Pharmacy .

Innovation

Truepill works alongside highscale pharmaceutical providers through the use of technological healthcare advancements. Working mainly with telehealth clientele, Truepill receives all prescription orders digitally. At Truepill’s distribution centers, online prescription orders are electronically vetted, with information sent to machines that fill individual prescriptions from wholesale medication supplies, and labels the prescription bottle with the appropriate information. This automation allows Truepill to work more efficiently than a traditional retail pharmacy. TruePill also offers a web-based API for businesses to monitor TruePill’s services .

Legal

December 2022

The Drug Enforcement Administration (DEA) holds a current investigation against Truepill for unlawful dispensing of stimulant medications. The DEA found "In numerous instances, Truepill dispensed controlled substances pursuant to prescriptions that were not issued for a legitimate medical purpose in the usual course of professional practice”, and discovered that over 60% of Truepill’s prescriptions had been for stimulants. The DEA had also found Truepill filling prescriptions that exceeded the legal 90-day supply limit, as well as filling prescriptions for prescribers without proper state licensing . Further investigation was performed upon Truepill’s attempted ADHD medication startup Ahead .

May 2022

The Department of Justice launched an investigation pertaining to Truepill’s potential violations of the Controlled Substances Act through Cerebral and fellow telehealth company Done. Following the investigation, Truepill halted the fulfillment of prescriptions for ADHD-related stimulants “out of an abundance of caution” .

COVID-19

Telehealth providers like Cerebral experienced a large client surge amidst the COVID-19 pandemic. In the US, mental health telehealth availability increased 77% between 2020-2021 . Cerebral specifically cites itself as “especially critical” during the COVID-19 pandemic, which prevented access to in-person care.

Ryan Haight Online Pharmacy Consumer Protection Act

The Ryan Haight Online Pharmacy Consumer Protection Act was passed in 2008 and aimed to narrow the guidelines within the Controlled Substances Act in which a patient can be prescribed controlled substances via telehealth .

In January 2020, The Department of Justice loosened remote prescribing restrictions of Schedule II through Schedule V controlled substances until the conclusion of the COVID-19 public health emergency declared by the Secretary of Health and Human Services. As of January 2023, the act continues to be lifted .

Allowing the prescription of Schedule II controlled substances through telehealth allowed Cerebral to widely expand its market to diagnosing and treating patients with ADHD and/or anxiety-adjacent mental health difficulties. However, Cerebral halted Schedule II controlled substance prescription for new clients in May 2022, and for existing patients in October 2022 “in anticipation of the end of the public health emergency waiver to the Ryan Haight Act” .

Controversy

Advertising

Discussion pertaining to Cerebral has been widely influenced by the brand’s social media marketing techniques. Cerebral offers direct-to-consumer medical marketing, listing symptoms of mental health issues the company provides services for. Unlike drug manufacturers, telehealth connectors like Cerebral are not required to adhere to the advertising regulations set by the Food and Drug Administration. Instead, Cerebral is required to remove branded medication titles from its advertisements .

Many of Cerebral’s controversial advertisements revolve around the company’s diagnosis services for ADHD. One Cerebral ad that was removed from social media platforms included false connections to ADHD and obesity, including an advertisement mentioning diabetes. Another ad lists inaccurate diagnosis criteria for ADHD asking the viewer if they had experienced said symptoms. Cerebral’s competitor company Done has faced similar critiques of advertising for ADHD telehealth and prescription services.

Removal

Cerebral has faced criticism for its deceptive advertising targeting social media applications with younger viewing audiences, such as Tik Tok . Cerebral has also been criticized for encouraging self-diagnosis on said platforms, leading users to be encouraged to seek prescription treatment through Cerebral.

Multiple social media sites, including "TikTok" and Meta, have removed Cerebral advertisements from their platform. Examples of removed advertisements include an early 2022 Cerebral advertisement linking obesity to ADHD. In response to the removed advertisements, Meta’s spokesperson announced “We don’t allow content that promotes misleading health claims or that attempt to generate negative self-perception in order to promote health-related products. We remove ads that break these rules” .

Advertisement spokesperson and Olympic gymnast Simon Biles stepped down as Cerebral’s “chief impact officer” in December 2022 without comment. Biles has been removed from all Cerebral advertisements .

Cerebral Advirtisement

In response, Cerebral stated that an outside advertising agency created and published the removed ads. Chief medical officer Dr. David Mou assured that the removed ads were pulled from Cerebral’s advertisement circles .

Legal

Truebe v. Cerebral, Inc.

Former Cerebral Vice President Matthew Truebe filed a lawsuit against Cerebral on April 27, 2022, claiming the company encouraged profits to come before patient quality care and safety . Truebe cited Cerebral’s demand to increase customer retention by prescribing stimulants to all patients with ADHD, failure to respond to emergency situations such as suicidal expression, and the requirement to increase clientele while simultaneously lacking appropriate practitioners as reasons for legal actions. Truebe further stated that Cerebral acted in retaliation of his concerns while employed, cutting Trube’s stocks in the company in half and requiring him to sign a compliance amendment.

DOJ Investigation

Beginning May 4, 2022, Cerebral was investigated for potential violations of the Controlled Substances Act by the Department of Justice . The DOJ investigation was produced in response to a March 2022 report on Cerebral by the Wall Street Journal. Following the investigation, Cerebral independently halted the prescription of Schedule II controlled substances. Previous pharmacy partners CVS and Walgreens no longer accept prescriptions from Cerebral in response to the company’s investigation and response.

Wall Street Journal Report

The Wall Street Journal published one of the first employee-cited reports on Cerebral on March 26, 2022 . The Wall Street Journal report held claims from nurses who had worked with Cerebral who expressed discomfort with the company’s practices. Cerebral practitioners expressed that they felt pressured to schedule medication, specifically stimulants for ADHD. The report also states that practitioners did not feel as though Cerebral’s 30-minute patient interview was adequate for the diagnosis of ADHD. The Wall Street Journal notes that Cerebral operates as a “Silicone Valley Startup” by encouraging large consumer demand for medication and mental health services.

FTC Investigation

Beginning June 15, 2022, the Federal Trade Commission published an active investigation into Cerebral . The FTC investigation aims to conclude if Cerebral had participated in deceptive practices related to medical advertising. Subscription and billing services are the main investigatory practice within the FTC’s investigation. Following the FTC’s Investigation Demand, Cerebral’s board voted to remove co-founder and previous CEO Kyle Robertson.

Buisness Insider Report

Buisness Insider published a report on Cerebral that included investigatory reviews on confidential buisness documents (“company policies, internal communications, meeting agendas, memos, and about 2,060 incident reports filed by employees from seven months in 2021”) and interviews with Cerebral employees . Buisness Insider showcased Cerebral pairing patients with family medicine practitioners inadequate at treating patients with more complex mental health struggles, leading to marked misdiagnoses and hazardous medication prescriptions. Cerebral employees stated that corresponding incident reports were never confirmed to be received or reviewed. Cerebral responded by stating that marked misdiagnoses are telling of quality care and represent a “relatively small group” .

Former employees stated to Buisness Insider that Cerebral’s practices have the ability to threaten practitioners' state licenses, as the company bypasses state regulations by taking advantage of federal allowances. Nurses also faced employment scrutiny at Cerebral if not meeting metrics for prescription outputs. Buisness Insider additionally published interviews by former Cerebral recruiters stating that they were forced to conduct shorter interviews to hire more practitioners, leading to a decreased quality of clinical care. The report further reflects these statements by showcasing messages from patients to Cerebral: some were prescribed potentially lethal combinations of medication, some were prescribed controlled substances while trying to maintain sobriety, and some were prescribed above the legal dosage. Buisness Insider similarly discovered more than 2,000 duplicate patient profiles and shipping addresses.