A telehealth practice has the hardest version of the compounding logistics problem: prescribers in a few states, patients in many, and every prescription shipped to a home address. Each prescription has to reach a pharmacy that prepares that product and is licensed in that patient's state. Since the FDA's 2026 enforcement actions, the practice also has to be able to show that each prescription was an individual clinical decision and not an item picked from a menu.
This guide covers how patient-specific ordering works for telehealth companies on ScriptLinkRx and what the FDA's 2026 actions mean for platform-based prescribing.
Telehealth is the patient-specific pathway
Medication shipped to a patient's home is dispensed on a prescription for that patient, which is the 503A pathway. Office-use stock from 503B outsourcing facilities is meant for administration in a clinic and does not fit a ship-to-home model. The 503A vs 503B guide explains the two.
Three layers of licensing apply to every order:
- The prescriber generally has to be licensed in the state where the patient is located at the time of the visit.
- The pharmacy needs an active license in the state it ships to, which usually means a non-resident license.
- The visit has to meet that state's standard for establishing a prescriber-patient relationship by telehealth. States differ on whether a questionnaire alone is enough.
ScriptLinkRx handles the second layer. Each partner pharmacy records the states where it is licensed, and once a patient is selected the catalog only shows products from pharmacies that can ship to that patient's state. The first and third layers remain the practice's responsibility. The partner pharmacy list shows each pharmacy and its licensed states.
What the FDA's 2026 actions mean for telehealth
Compounded GLP-1 programs are the focus of the FDA's current enforcement. The September 2026 warning letter to a large compounder made three points that reach telehealth directly:
- Volume reads as pretext. The letter stated that the volume being produced suggested the differences from the approved products were pretextual.
- Templated justifications fail. The FDA flagged boilerplate significant-difference language and prescriptions with no determination at all.
- Platforms are in scope. The letter pointed to third-party platforms that offer prescribers pre-selected options as part of the problem.
A model in which the patient picks a product and a prescriber approves a fixed formulation sits close to what the letter describes. A workflow that holds up puts the clinical decision first: the prescriber evaluates the patient, decides whether a compounded product is needed instead of the approved one, records the reason for that patient, and writes the prescription. The GLP-1 sourcing guide sets out the current rules.
Marketing is part of the same picture. Compounded medications are not FDA-approved and should not be presented as generic or equivalent versions of an approved brand.
How an order flows
- Select the patient. Patient records live in the platform, with address validation so the pharmacy ships to a deliverable address the first time.
- Choose from one catalog. The catalog is filtered to the patient's state, and each pharmacy's price is visible before checkout.
- Prescribe and submit. The prescriber writes and signs the prescription, with directions and clinical notes for that patient. The platform does not generate justification language or pre-select a formulation.
- Collect payment. Send the patient a secure payment link, or pay as the practice and bill the patient yourself.
- Track to the door. The pharmacy reviews, compounds and ships. The patient receives tracking, and refills are managed from the same record.
Controlled substances
Testosterone and other controlled substances add federal rules on top of state telehealth law. The Ryan Haight Act generally requires an in-person medical evaluation before a controlled substance is prescribed, with exceptions and telemedicine flexibilities that the DEA has revised repeatedly since 2020. Confirm the current DEA position before prescribing a controlled substance to a patient no prescriber has examined in person.
On ScriptLinkRx a controlled substance is ordered from the catalog like any other product. The prescriber also sends the prescription to the dispensing pharmacy from their own e-prescribing software, and the order page names the pharmacy to send it to. The TRT guide covers testosterone specifically.
Records that hold up
When a board or the FDA asks how a prescription came about, the answer has to be in the record. On ScriptLinkRx clinical notes and directions are entered per patient and travel with the order, and order, prescription and receipt records are retained per patient and per practice. Pharmacy licensing is recorded on the platform, so an order is not routed to a pharmacy that cannot lawfully ship to the patient. Partner pharmacies may decline prescriptions that do not meet their own compliance review.
Sources
- FDA: FD&C Act Provisions that Apply to Human Drug Compounding (sections 503A and 503B)
- FDA: Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A (guidance)
- FDA: FDA clarifies policies for compounders as national GLP-1 supply begins to stabilize (April 2026)
- FDA: Warning Letters (search "Empower Clinic Services", September 18, 2026)