The buy button is the problem, not the consult.
The most common GLP-1 storefront we are asked to review has the same shape. A product page for semaglutide or tirzepatide with a price on it. An add to cart or buy now button. A checkout. Then a line somewhere saying a licensed provider will review your information before anything ships. The founder's view is that the consult happens before the prescription, so the order is fine.
LegitScript's seventh certification standard reaches earlier than that. It does not only govern when a prescription may be written or a drug dispensed. It governs when a drug may be offered. A buy button on a prescription drug is an offer, made on the page the visitor is looking at, before any intake, any consult or any prescription.
Our own intake and checkout guide says there is no universal answer to whether a visitor should book, pay or qualify first. For a prescription drug, there is. Standard 7 fixes it.
What does Standard 7 say?
LegitScript publishes nine standards for Healthcare Certification on its own site. The seventh is titled Validity of Prescription, and it reads, in full:
"The applicant shall only dispense or offer to dispense prescription drugs upon receipt of a valid prescription issued by a person authorized to prescribe under applicable laws. A valid prescription is defined by applicable statutes, regulations, or laws in the jurisdictions served by the applicant. Applicants must not prescribe, offer to prescribe, distribute, or offer to distribute drugs in a way that violates the laws of the jurisdiction(s) they serve, and must comply with all relevant telemedicine laws or regulations, as applicable. A prescription or prescription drug must not be prescribed or dispensed prior to the provision of care by a licensed medical professional."
The sentence that decides what your product page can do is the first one. The condition on offering to dispense is the same as the condition on dispensing: receipt of a valid prescription. The third sentence does the same for prescribing. It reaches the offer, not only the act.
LegitScript does not define "offer" and decides compliance in its sole discretion. What follows is how we read the text and build to it.
Why does "offer to dispense" land on the product page?
A page that names a prescription drug, puts a price next to it and lets a visitor pay for it is offering to dispense that drug. The visitor has not been evaluated. No prescription exists. The condition the standard attaches to the offer cannot be met by a public page, because the page is the same for every visitor and a prescription is specific to one patient.
This is not a strained reading of LegitScript's concerns. In its 2024 FAQ on GLP-1 sales online, LegitScript listed the violations it monitors and reports to platforms, and one of them is "GLP-1 drugs being offered for sale without a prescription". Offered for sale, not sold. The same FAQ said 15 percent of the problematic GLP-1 ads it had flagged were offering the drugs without a prescription. And in the certification terms the applicant agrees to "advertise, offer, and distribute its products and services in compliance with all applicable laws". Advertising and offering sit beside distributing, as things the program reaches.
Is the problem the sequence or the wording?
Both, and they fail different sentences.
Add to cart, pay, consult, ship. The page sells a named prescription drug. The visitor pays. A provider reviews afterward. This fails the first sentence, because the offer to dispense was made and accepted before a prescription existed. What the site sold was a prescription drug, to a person no licensed professional had seen.
Questionnaire in, prescription out. The page may sell the right thing, but the "consult" is a form whose completion produces a prescription. This fails the last sentence, because nothing a licensed medical professional would recognize as care happened first. LegitScript's own blog framed the question this way in June 2026: "LegitScript Certification requires licensed providers to deliver care before any prescription is issued." Justin Champion, the CEO of White Label MD, drew the line in that interview at "the questionnaire-only model where a patient fills out a form and a prescription is generated with no genuine provider review, or where the 'review' is a rubber stamp".
Pay for the visit, prescribe if appropriate, then charge for medication. The page offers care. The provider decides. Medication is charged only once a prescription exists, by the pharmacy or as a separate step. This is the shape that fits the text, and it is the business LegitScript's own eligibility page describes: a digital health platform that "facilitates the sale of prescription medicines by connecting patients with medical providers and contracted pharmacies". Facilitating the sale is the certified business. The order of operations is what the standard controls.
Does Standard 7 ban asynchronous care?
No. The standard says care by a licensed medical professional. It does not say a video call. An asynchronous model where a licensed provider reads a structured intake, labs and history and makes a real prescribing decision is care, and the White Label MD interview says as much: asynchronous care "can absolutely meet that bar".
What the standard does require is compliance with the telemedicine law of each jurisdiction served, and the certification terms sharpen it. The applicant agrees that "except where expressly permitted by law or regulation, a valid prescription requires that the prescribing practitioner, or a covering practitioner, have physically examined the patient in person prior to issuing a prescription". Telemedicine is the exception, and it exists state by state. The same interview notes that some states require a synchronous video or phone component for certain prescriptions. That is why the state gate runs before the intake, which is the architecture in hard-stop contraindication logic before payment. That post makes the case on safety and refunds. This one adds certification.
What about "pay now, full refund if you are not prescribed"?
The refund does not change what the page offered. If a visitor paid for a named prescription drug before any licensed professional saw them, the site offered to dispense a prescription drug without a valid prescription. The refund is a remedy for the patient, not for the standard.
It also creates a second problem. Standard 8, Transparency, requires that "all practices and offers are accurate, transparent, and not misleading to patients or the public", and names "financial transactions" among the material details. A charge for semaglutide that is really a charge for a consultation, refunded if the consultation goes one way, does not describe the transaction. And every refund is a line your payment processor reads.
What does the page look like when it passes the text?
The build is a set of decisions about what carries a price and what carries a button.
- The medication page is an information page. What the drug is, who it is and is not for, that a licensed provider decides, and, for compounded versions, that compounded drugs are not FDA approved. No price on the drug, no cart.
- The primary button starts the eligibility check. "Check eligibility" or "Start your visit", not "Add to cart". It leads to the state gate, then the intake.
- The thing with a price is the visit or the program. A consultation fee, a program fee or a membership is an offer of care, and it can be sold on a public page.
- Medication is charged after the prescription. By the pharmacy, or as a separate step triggered by the prescription. The receipt names what was bought.
- Nothing on the storefront is a purchasable drug. If the fulfillment stack needs a product record for the pharmacy order, it stays out of the public catalog and out of search.
- The same shape holds everywhere you control. Standard 4 requires the applicant to provide all domain names and websites under its control, so an old landing page with a buy button is in the review. The web developer's checklist covers the domain inventory.
What to do before you apply.
Google's healthcare and medicines policy, in its United States section, allows telemedicine providers to advertise "if they're accredited by LegitScript's Healthcare Merchant Certification Program", so a Standard 7 failure closes that lane before the ad account is involved.
- Load every medication page and ask whether a visitor could pay for the drug from it. If yes, that page is an offer to dispense.
- Move the price to the visit or the program, make the primary button start the eligibility check, and confirm the stack runs state gate, intake, provider decision, prescription, then the medication charge.
- Run the same check on every domain, subdomain and logged-in page you control.
This is operational and web architecture guidance, not legal advice. LegitScript decides certification against its own standards and in its own discretion, and nothing here predicts its decision on your site. ToolBX Media is a LegitScript partner, and this check is part of the readiness pass we run before a submission. Score your own site with the LegitScript readiness score, read the surrounding questions in the LegitScript and med spa FAQs, or have us look at the storefront and the stack together in a telehealth program fit review.
Common questions
What does LegitScript Standard 7 actually say?
Standard 7 is the seventh of LegitScript's nine Healthcare Certification standards and is titled Validity of Prescription. It has four sentences. The applicant may only dispense or offer to dispense prescription drugs on receipt of a valid prescription from someone authorized to prescribe. A valid prescription is whatever the laws of the jurisdictions served define it to be. The applicant must not prescribe, offer to prescribe, distribute or offer to distribute drugs in a way that violates those laws, and must comply with telemedicine law. And a prescription or prescription drug must not be prescribed or dispensed before a licensed medical professional has provided care.
Can a telehealth site put an add to cart or buy now button on a prescription medication page?
Not without a valid prescription behind it, which a public product page never has. Standard 7 conditions the offer to dispense, not only the dispensing, on receipt of a valid prescription. A page that prices a prescription drug and lets a visitor pay for it is offering to dispense that drug to a person no licensed professional has evaluated. The pattern that fits the text sells the visit, the program or the membership, and lets the prescription decide whether there is a medication to charge for afterward.
Does Standard 7 ban asynchronous or questionnaire-based telehealth?
No. The standard requires care by a licensed medical professional before anything is prescribed, and it requires compliance with the telemedicine laws of each state served. It does not say the care has to be a video call. An asynchronous model where a licensed provider reads a structured intake and makes a real prescribing decision is care. A questionnaire that generates a prescription with no genuine provider review is not. Telemedicine rules differ by state, including whether a live visit is required, so the state gate has to run before the intake does.
Can I take payment for the medication first and refund patients who are not prescribed?
The refund does not change what the page offered. If a visitor paid for a named prescription drug before any licensed professional saw them, the site offered to dispense that drug without a valid prescription, and that is the offer Standard 7 forbids. Refunding the people who are declined also means the visible transaction does not describe what was sold, which runs into Standard 8 on transparency, and it produces the refunds and chargebacks that a payment processor reads as a risk signal. Charge for the consultation or program up front, and charge for medication once a prescription exists.
What does a compliant GLP-1 product page look like?
The medication page is an information page. It says what the drug is, who it is and is not for, that a licensed provider decides whether to prescribe, and, for compounded versions, that compounded drugs are not FDA approved. Its primary button starts the eligibility check or intake rather than adding a drug to a cart. The thing with a price attached is the visit or the program. Medication is charged after a prescription is issued, by the pharmacy or as a separate step, and the receipt names what was actually bought. The same shape has to hold on every landing page, subdomain and logged-in page the business controls, because the application requires all of them to be disclosed.
Sources
- LegitScript, Healthcare Certification, the nine certification standards including Standard 7, Validity of Prescription checked 2026-10-21
- LegitScript, Healthcare Merchant Certification Terms and Conditions, section on prescribing or dispensing prescription drugs and telemedicine checked 2026-10-21
- LegitScript blog, What It Really Takes for Weight Loss and Longevity Clinics to Get LegitScript-Certified, a Q&A with White Label MD, 19 June 2026 checked 2026-10-21
- LegitScript, GLP-1 Sales Online, What You Need to Know, 17 July 2024 checked 2026-10-21
- Google Ads policy, Healthcare and medicines, United States section on online pharmacies and telemedicine checked 2026-10-21
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