Legal, Governance & Compliance
When a 501(c)(3) partners with a commercial licensor and government laboratories, the structure has to satisfy tax, procurement, and healthcare privacy standards.
| Regulatory domain | Requirement | Operational implementation |
|---|---|---|
| IRS 501(c)(3) and UBIT | Charitable mission fit | Program-related activity; lessening the burdens of government |
| Private inurement / benefit | Arms-length relationship | Free license / pass-through cost |
| Government procurement | FAR / 2 CFR 200 bidding rules | Zero-cost software acquisition |
| HIPAA / HITECH | BAA and privacy safeguards | 45 CFR 164.512(b); AI on Amazon Bedrock under a signed AWS BAA |
| FedRAMP / StateRAMP | Government-grade hosting | Not claimed; scoped per agency during procurement |
1. IRS 501(c)(3) and UBIT
Advancing public health and assisting government agencies in disease surveillance fulfills a tax-exempt charitable purpose: lessening the burdens of government under Treas. Reg. § 1.501(c)(3)-1(d)(2).
The software license is given at $0.00, so there is no commercial sale. Cloud hosting is a pass-through reimbursement without markup. Maintenance fees charged to agencies represent direct cost-recovery for program-related services (IRC § 513(a)).
2. Private inurement and the license deed
JIL Sovereign Technologies, Inc. operates this host. salusagentic.com is part of JIL Sovereign Technologies, Inc., a Delaware corporation. SalusAgentic is a trade name of that company. JIL Sovereign Holdings, LLC (WY) owns the SalusAgentic software. Global Hands, Inc. (TX) gave a grant to JIL Sovereign Holdings, LLC (WY) to build salusagentic.com under its public good initiative. The cost to build SalusAgentic was greater than what Global Hands paid. Global Hands may benefit from the software because it gave Holdings that money. JIL Sovereign Technologies, Inc. (DE) operates and supports salusagentic.com. JIL Sovereign Technologies, Inc. (DE) operates most, if not all, of the software JIL Sovereign Holdings, LLC (WY) owns. Global Hands, Inc. does not operate this site. SalusAgentic is a trade name of that company, not a separate corporation. Maintenance paid to technical contractors must be documented at or below fair market value.
3. Government procurement
Because the core software license is $0.00, government agencies do not need to conduct a formal software-acquisition RFP for the license itself. Pass-through cloud hosting and maintenance can proceed as simplified acquisition, a cooperative agreement, or a sole-source non-profit grant, subject to each agency's counsel.
4. HIPAA, HITECH, and public health exceptions
Covered entities are authorized under 45 CFR § 164.512(b) to disclose PHI to public health authorities for disease prevention and control without individual patient authorization. Where Salus Agentic processes identifiers on behalf of a covered entity, confirm the Business Associate Agreement signatory with the operator.
5. Cloud hosting and data sovereignty
The hosted service stores laboratory data in PostgreSQL. AI-assisted features call Amazon Bedrock, which AWS provides under a signed Business Associate Agreement. SOC 2 Type 1 is targeted for December 2026. SOC 2 Type 2 is targeted for January 2027. HIPAA is targeted for January 2027. HITRUST r1 has started, and completion is targeted for March 2027. The examinations are in progress under JIL Sovereign Technologies, Inc. (Delaware) with Johanson Group LLP. The reports are not issued. Salus Agentic does not claim a FedRAMP or StateRAMP authorization, and it does not claim certifications held by infrastructure it does not run on. An agency that requires a specific authorization should raise it during procurement so the deployment is scoped to that requirement.