Can I say “no prescription needed” in a telehealth ad?

CG-TRG-005 · Blocks approval · Citation checked against stored text

Prescribing or shipping across state lines without a licensed exam, lay owners directing physicians, naturopaths using the MD title or treating cancer, cannabis recommendations without an exam, treating minors without parental consent, and implied state endorsement violate state licensure, corporate practice and advertising laws.

Source: State medical practice acts (including California Business and Professions Code 2052, New York Education Law 6512, Texas Occupations Code 155 and 165); corporate practice of medicine doctrine; Ryan Haight Online Pharmacy Consumer Protection Act, 21 U.S.C. 829(e); state naturopathic licensing acts; FTC Act section 5

Safer wording: Offer care only through clinicians licensed in the patient's state after a proper exam, use only titles the licensee holds, never imply state endorsement, and get parental consent for minors.

21 U.S.C. 829 · Needs counsel review

CG-TRH-005 · Warns · Citation checked against stored text

Offering prescription or controlled medications without an exam, labs, history or physician involvement, or letting non-physicians adjust doses by text, markets prescribing outside the standard of care and bypasses safeguards.

Source: Ryan Haight Online Pharmacy Consumer Protection Act, 21 U.S.C. 829(e) and 802(54); DEA telemedicine rules; FTC Act section 5; state medical board telemedicine standards

Safer wording: Describe a real clinician evaluation, including history and appropriate testing, before any prescription, and never advertise prescribing without exam or with unsupervised dose changes.

21 U.S.C. 829 · Needs counsel review

CG-PLT-034 · Warns · Citation checked against stored text

Quora restricts healthcare advertising, including prescription and over the counter medication, GLP-1 medications, online and offline pharmacies, and clinical trial recruitment. These need Quora's approval before the ad runs. This is platform policy, not law, and an ad can be rejected without it.

Source: Quora Advertising Policies ("We restrict the promotion of healthcare-related content."; "We restrict GLP-1 medications.")

Safer wording: Ask Quora for approval with your company name, the product or service and the landing page before you run the ad. Appointment booking sites, basic medical supplies and online therapy apps do not need prior approval.

Quora Advertising Policies

CG-RPL-002 · Warns

Offering prescription products with no clinician evaluation is a legal and safety problem, and wrongly implies no oversight.

Source: FDCA 503(b) (prescription-only drugs); state telehealth and practice laws; FTC Act section 5

Safer wording: Explain how a licensed clinician evaluates each patient and decides whether a prescription is appropriate.

See source text · Needs counsel review

CG-RPL-004 · Blocks approval

Telling people to stop medication or skip surgery, chemotherapy or a doctor is a safety risk, and implying doctors hide the truth is a deceptive framing.

Source: FTC Act section 5; FTC Health Products Compliance Guidance

Safer wording: Say the product or service is not a substitute for care from their clinician, and that they should talk to their clinician before changing any treatment.

See source text · Needs counsel review

CG-TRL-003 · Warns

Offering a generic or lookalike of a brand GLP-1 drug, or supplying it with no diagnosis or prescription, misrepresents regulatory status and promotes a prescription drug without an evaluation.

Source: FDA Federal Food, Drug, and Cosmetic Act sections 301 and 503(b) (prescription drugs; no FDA-approved generic of Ozempic or Wegovy); FDA warnings on compounded and counterfeit GLP-1 products; FTC Act section 5

Safer wording: Do not call any product a generic version of a branded GLP-1. State that a licensed clinician must evaluate you and prescribe, and describe compounded products accurately.

See source text · Needs counsel review