Sources: health startups Cerebral and Done used looser pandemic rules and pressure on clinicians to prescribe stimulants, often via 30-minute online evaluations
Context & Ripple Effects
This March 2022 Wall Street Journal report was the opening move in an enforcement arc that has since caught up with both companies named in it. It documented how Cerebral and Done built ADHD prescription volume on pandemic-era federal flexibilities for controlled substances, with clinicians pushed toward prescribing after 30-minute online evaluations.
What followed validated the sourcing: documents later showed Cerebral grew the same ADHD drug business through a social media advertising playbook now drawing federal prosecutor interest over possible Controlled Substance Act violations, while Done's founder was ultimately arrested in June 2024 on allegations of running a "pill mill" — with the company still operating from China.
First-order effects
- Clinicians at Cerebral and Done were working inside a prescribing pipeline where short online evaluations and internal pressure substituted for traditional psychiatric assessment, putting their licenses and judgment at the center of the startups' growth model.
- Both companies' rapid patient acquisition depended directly on pandemic-era rules that loosened how controlled substances like stimulants could be prescribed remotely — rules they had no incentive to see tightened.
Second-order effects
- Federal prosecutors' interest in possible Controlled Substance Act violations at Cerebral turned a growth-story startup into a compliance case study, forcing every venture-backed telehealth prescriber to re-examine whether its own funnel looks the same.
- Done's trajectory — from this reporting to its founder's arrest and continued operation from China — shows the downside risk extending past fines into criminal exposure and cross-border flight of the operators themselves.
Third-order effects
- If the pattern holds, the pandemic flexibilities that enabled not just stimulant but also online ketamine prescribing become the next battleground between telehealth's access argument and regulators' control over Schedule II and III drugs.
- Telehealth prescribing businesses structurally split into two camps: those whose unit economics survive stricter in-person evaluation requirements, and those — like Done — whose model only worked when the evaluation was the bottleneck being removed.
The trend: Venture-backed telehealth is learning that pandemic-era prescribing flexibility was borrowed regulatory capital, and enforcement — from prosecutor inquiries to arrests — is now calling it due.