AI Delivery Ownership | Portfolio companies in regulated industries

The company owns the AI system. MVP builds and runs it.

Most portfolio companies with a credible AI use case have no team to build it, and hiring one first is a big bet. MVP provides the engineers and a method for building the system, with security and compliance work included. The company owns the code, data, and accounts from day one. A buyer’s diligence team will check that ownership at exit.

The Gap

A clear use case, but no team to build the system.

The starting point is much the same across regulated industries: a workflow with large document volumes or slow manual steps that runs on patient, client, or financial records. There is no engineering team, and leadership wants the company to own whatever gets built.

The two obvious answers both fall short. Hiring an AI engineering team before the first system exists is more risk than most lower middle market companies can take on. Handing the build to a software vendor leaves the company dependent on code and know-how it does not own.

Why Ownership Matters

A company has to own any AI system that drives its revenue or margin.

The system keeps changing.

Regulations, contracts, and workflows change every quarter. When a vendor builds the system and leaves, nobody inside the company can change it.

What the buyer will examine at exit.

At exit, the buyer’s diligence team will ask who owns the code, the data, and the operating knowledge, and who can keep the system running.

Regulatory duties stay with the company.

Under HIPAA and rules like it, the company keeps its duties for regulated data, and the risk that comes with them, even when someone else writes the code.

The Model

The company keeps the system. MVP does the work until the company can.

Regulated companies already outsource production while keeping ownership. This works the same way: the company owns the system and sets the requirements, while remaining accountable for its regulated data. MVP supplies the people and a disciplined method for building and running the system. That includes a security baseline, a reference architecture, written decisions on vendors and data agreements, and go-live checks that hold up in a security review, an audit, or diligence.

In healthcare, Anthropic, OpenAI, AWS, and Microsoft all offer BAA-covered routes, but coverage varies by product, platform, and feature. Vendor documentation does not always agree, so MVP confirms coverage for the exact route in writing before any patient data moves. Development uses synthetic or properly de-identified data, so contractors never touch production PHI.

How It Works

One technical owner, accountable from discovery through transfer.

For operating partners: the second portfolio company starts from the first one’s playbook and reference architecture.

Why Mulligan Valley Partners

Christian Busch has built on patient data at scale and gotten a company through health-system security reviews.

At Elevance Health, Christian Busch led product for the AI/ML platform built on FHIR R4 lifetime patient records for 70 million members, on a zero-trust architecture across AWS and GCP. The prior authorization engine he built there combined OCR document intake, FHIR data, and guideline-derived decision trees, and cut decisions from days to seconds.

At a U.S. medical-device manufacturer, he built the cybersecurity and IT compliance program, with the roadmap and budget for ISO 27001, HITRUST, and NIST 800-53, that carried the company through health-system security reviews. He holds the CISSP.

Christian also runs Inoculis, a fractional CIO and CISO practice for medical device, SaMD, IVD, and digital health companies.

Send the use case.

If you are an operating partner or a portfolio CEO with an AI use case and no one to build it, send a short line on the company, the workflow, and the data involved.

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