Acceptable Use Guidelines

Version 3.1 · Effective May 2026

Nautilus Health Institute is a 501(c)(3) nonprofit organization that advances transparency and fiduciary accountability for employer plan sponsors by providing independent, standards-based analysis of benefits contracts. Contract X-Ray is the platform and methodology Nautilus maintains for evaluating benefits contracts against Fiduciary-Aligned Contract Standards.

These guidelines protect three things at once: the employer, whose analysis serves their fiduciary duty and not someone else’s commercial purpose; the methodology, whose credibility depends on independent and consistent application; and the work itself, against repurposing in ways that conflict with the mission. Every guideline that follows traces back to one of those three protections.

Scope. These guidelines apply to anyone who submits a contract for analysis or receives an analysis output. They are written for advisors who submit on behalf of employer clients, where the operational rules have the most substance. Employer plan sponsors submitting directly are bound by the same standards in the sections that apply to them. This document covers contract submission and use of reports. It does not cover brand and co-marketing rules or network partnership terms, which are governed by the Network Partner Program. If a submission flows through a Network Partner, additional terms apply under that separate agreement.

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Pre-submission conduct

How you represent yourself and Nautilus before a contract is submitted matters as much as what you do with the analysis afterward.

  • OK Submit contracts you already have access to through an existing client relationship or a FOIA or public records request you filed as an individual.
  • OK Tell a prospective client you use Contract X-Ray as part of your process and describe how the methodology works.
  • NO Represent yourself as acting on behalf of Nautilus Health Institute, or as a Nautilus agent, representative, or affiliate, when approaching any employer, government entity, or PBM.
  • NO Use Nautilus’s name, nonprofit status, 501(c)(3) designation, or scoring methodology as a reason for an employer or government entity to produce, share, or disclose a contract.
  • NO Solicit contracts from organizations with which you have no existing client relationship, using Contract X-Ray participation as the basis for the outreach.
  • NO Represent to any PBM that a client contract has been or will be submitted to Contract X-Ray without that client’s consent.
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Delivering analysis to your client

Each analysis is produced for one employer client and serves their fiduciary work. The deliverables stay inside that engagement.

  • OK Share the Contract Scorecard and other reports (Negotiation Report, Executive Brief) with the employer client whose contract was analyzed.
  • OK Discuss findings, scores, and recommendations directly with that client and their legal counsel or advisors.
  • NO Share one client’s analysis, score, or any finding from their contract with any other employer, prospect, or third party without that client’s consent.
  • NO Retain or use client contract files for any purpose other than the analysis engagement for which they were submitted.
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Cross-client information

Each analysis is confidential to the client engagement that produced it. Scores, findings, and contract language from one client may not inform work on another.

  • OK Reference published tier designations and ratings for PBMs whose results are publicly available.
  • OK Use published market statistics (for example, “68 percent of contracts score Red Flag on audit rights”) in presentations and proposals.
  • NO Tell Client B what Client A scored, even without naming Client A. Relative disclosures (“I have seen neighboring counties score much lower”) are prohibited.
  • NO Tell a PBM what a specific client’s contract scored without that client’s consent.
  • NO Use one client’s analysis to benchmark or frame a proposal to another client.
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Marketing and business development

How you describe Contract X-Ray in the market shapes how the methodology is understood. Accurate description is fine; implied endorsement is not.

  • OK Describe Contract X-Ray as a tool you use and explain what it measures.
  • OK Reference publicly available market data and PBM tier designations in presentations and proposals.
  • OK State you have submitted contracts and worked with clients through the analysis process, without disclosing any specific client or score.
  • NO Claim any score, finding, or client outcome as a marketing statistic without that client’s consent.
  • NO Represent Contract X-Ray as an endorsement, certification, or recommendation of any PBM or plan design.
  • NO Use the Contract X-Ray name and branding, the Nautilus name and branding, or the name of any report or index in marketing materials without Nautilus’s prior approval.
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FOIA and public record contracts

Government employer contracts obtained through FOIA or comparable open records laws are public record. The analysis Nautilus produces from them is not.

  • OK Submit publicly available contracts for analysis on behalf of the employer or as part of a market assessment engagement.
  • OK Share the original contract document with clients, since it is public record.
  • NO Share the Contract Scorecard, Contract Reports, or any analysis deliverable with anyone other than the organization for whom the analysis was conducted.
  • NO Use analysis of Government Employer A’s contract to inform advice to Government Employer B, even if both are in the same jurisdiction.
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Funding the mission

Quick Look is free. Full Assessment operates on a voluntary contribution model with a sustainability floor and a suggested contribution that scales to employer size. Specific contribution amounts are presented during the intake process.

For employer plan sponsors submitting directly, the contribution decision rests with the employer. For advisors submitting on behalf of an employer client, the rules below apply.

  • OK Present the voluntary contribution model, the size-based suggested amount, and the floor to the employer client before submission, as they appear in the intake.
  • OK Make the contribution on behalf of the employer client when the client is informed that a contribution exists and that the advisor is making it.
  • NO Represent the analysis as free, as included in advisor service fees, or as something the advisor provides at no cost to the client.
  • NO Solicit, collect, hold, or route contributions outside the Nautilus payment system.
  • NO Quote the employer client a suggested amount different from what is published in the intake.
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Consequences of violation

These guidelines are a condition of participation in Contract X-Ray, not a recommendation. Violations carry real consequences.

Violations may result in

  • Immediate suspension of access to Contract X-Ray and all analysis deliverables.
  • Permanent removal from Contract X-Ray participation.
  • Notification to affected employer clients at Nautilus’s discretion.
  • Referral to applicable regulatory bodies or legal counsel if the violation involves misrepresentation of Nautilus’s nonprofit status or unauthorized use of its name.

Acknowledgment. If a use case is not addressed here, contact Nautilus before proceeding. When in doubt, treat client scores and analysis as confidential. Submission of a contract for analysis constitutes acknowledgment and acceptance of these guidelines as a condition of participation.

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