The purpose of this document is to provide an overview of guidelines that will help content creators, including partners and affiliates, talk about Levels and the CGMs we provide access to effectively.
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Levels is a general-wellness software company, and not a medical or healthcare company. From a legal perspective this distinction is really important. There are a few ways that you can help us keep the distinction clear.
We help our members get access to CGMs made by other companies — for example, Abbott’s Freestyle Libre, and DexCom’s G7 — but Levels doesn’t make its own CGM :) we sometimes hear people use the phrase “Levels CGM,” but it’s important to avoid this. It’s something regulators care a lot about: we have to make sure we don’t unintentionally give the false impression that Levels is a medical device company. Medical device makers are in a highly regulated industry that Levels is not a part of. If we or our affiliates inaccurately suggest we’re a device maker, regulators are allowed to treat us like one!
This point is related to the last one. Healthcare and medical devices are highly regulated fields with their own set of very specific rules and requirements. As a general wellness company, there are things Levels can do, and things that it is not allowed to do. It’s important that our affiliates don’t suggest Levels can do more than it can!
As you know, currently the Levels program is compatible with two different continuous glucose monitors: the Abbott Freestyle Libre, and the Dexcom G7. In order to help our members get access to these devices to use with Levels, there are a few restrictions that we and all of our affiliates must adhere to. We completely understand that these restrictions may be difficult, but at the end of the day, we’ve made the decision to shoulder them in order to serve our members, give them options, and help us conduct research studies that we hope will eventually improve the health and lives of people worldwide.
Let’s get the biggest one out of the way first: Neither we nor our partners can make any comparisons about the performance, quality, or clinical benefits between CGMs. This functionally means no comparing the different CGMs available through Levels.
This does not mean you can’t describe the devices in detail — but it does mean that you can’t discuss one CGM in relationship to the other.
<aside> 🤝 What about separate review videos?
If you want to do videos featuring individual CGMs, cool! But the videos should be self-contained, and not reference other CGMs. This includes referencing review videos about the other CGMs.
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This one is pretty simple: we help get members access to CGMs, but we and the manufacturers are not business partners. This is important to the manufacturers for their own regulatory reasons.
The best way to think about how Levels and Abbott/Dexcom CGMs work is compatibility: Levels is compatible with the Freestyle Libre the Dexcom G7.