What Is FDD Item 19 and Why Does It Matter for BrightSpring?

Item 19 of the Franchise Disclosure Document is titled “Financial Performance Representations.” Under the FTC Franchise Rule (16 C.F.R. Part 436), a franchisor is not required to include financial performance data in its FDD. However, if it chooses to make any financial performance claims, those claims must appear in Item 19 and must have a reasonable basis.

For BrightSpring, Item 19 matters because it is the only section of the FDD where you can find data about what existing locations actually earn. This data is essential for building a realistic financial model and determining whether the franchise investment can meet your return requirements.

What Financial Data Does BrightSpring Disclose in Item 19?

BrightStar Care provides financial performance representations based on net billings from qualifying franchised agencies. The data typically includes average and median figures and may segment performance by agency maturity.

The average revenue per BrightSpring unit is approximately Approximately $2.28 million (BrightStar Care system average). Item 19 data based on qualifying BrightStar Care franchised agencies.

Key metrics disclosed include: Average and median net billings for franchised agencies meeting specific operating criteria.

What the Numbers Mean for Prospective Franchisees

Revenue figures alone do not tell you whether a BrightSpring franchise is profitable. To assess profitability, you must subtract all franchise fees (disclosed in Item 6), operating expenses (labor, rent, supplies, insurance, utilities), and the cost of capital invested in the business.

What Does BrightSpring Item 19 Not Tell You?

Expense breakdowns, caregiver labor costs, insurance expenses, and net profitability are typically not included. Given that caregiver wages represent the largest expense (typically 45% to 55% of revenue), the gap between revenue and profitability is significant.

Additional information typically absent from Item 19 includes ramp-up period economics (new locations typically underperform system averages for 12 to 24 months), geographic variability (system-wide averages mask significant market-to-market differences), closures and failures (data may exclude locations that closed during the measurement period, creating survivorship bias), and owner compensation (whether disclosed operating margins include or exclude a salary for the owner-operator).

How Should You Interpret BrightSpring Item 19 Data?

At Lopes Law LLC, we advise clients to approach Item 19 with a specific analytical framework:

• Look at the median, not just the average. Averages can be skewed by outlier performers. The median tells you what a typical location earns.
• Model three scenarios. Optimistic (75th percentile), realistic (median), and conservative (25th percentile). Your investment must pencil at the conservative level.
• Subtract all Item 6 fees. Calculate net revenue after royalties, advertising, and technology fees to determine what you retain before operating expenses.
• Build your own expense model. Use local market data for labor, rent, insurance, and supplies. Do not rely on national averages.
• Account for the ramp-up period. New locations typically take 12 to 24 months to reach stabilized performance. Budget for below-average revenue during this period.

Why Franchise Validation Is Essential Alongside Item 19

Item 19 provides historical data reported by the franchisor. Franchise validation, the process of contacting existing franchisees to ask about their financial experience, provides essential real-world context. Contact at least 10 to 15 existing operators and ask about revenue trajectory, expense breakdown, ramp-up timeline, and overall satisfaction.

Item 21 of the FDD provides contact information for all current and recently departed franchisees. The franchisees who have left the system are often the most informative. For more on evaluating franchise opportunities, see our guide on franchise agreement red flags.

At Lopes Law LLC, our flat-fee FDD validation review is $3,000 and covers all 23 items, including detailed analysis of Item 19 and guidance on the validation process. For a complete overview, see our guide on what to expect from an FDD review. If you are evaluating an existing franchise, our franchise exit audit provides comprehensive analysis.

Frequently Asked Questions About BrightSpring FDD Item 19

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Last updated: March 12, 2026