GLP-1 screening on telehealth: what a defensible protocol includes

GLP-1 telehealth screening requirements are not written down in one place. No federal rule says which questions an online weight loss intake must ask, and state boards mostly describe the standard in general terms: a telehealth visit has to meet the same standard of care as an in-person one. That vagueness is why brands get it wrong in both directions, either asking almost nothing or adding so much friction that nobody finishes. This post describes what a defensible protocol looks like from a brand operator's side: a short list of questions the intake must ask, a lab policy, a titration and follow-up cadence, and the documentation that shows the standard was met. The licensed providers own all of it. The operator's job is to make sure it exists and that the platform enforces it.

What a secret shopper study found in online GLP-1 intake

In 2026 JAMA published a secret shopper study led by Ashwin Chetty, a medical student at Yale School of Medicine, in which researchers posed as an eligible patient and sought GLP-1 prescriptions from 49 telehealth websites between August and December 2025. Yale's announcement of the study reported that 45 of the 49 sites offered a prescription, and that only about half asked about eating disorders. Trade coverage of the paper in HCPLive reported that 34 of the sites shipped medication directly to the patient, that only a minority required a video or phone visit, and that several prescriptions were approved in five minutes or less. Of the four sites that declined to prescribe, two had required blood work first.

Read from an operator's chair, the study is a list of what a plaintiff's attorney or a board investigator will look for. The sites that drew criticism were not the ones that asked too much. A brand does not need to be the strictest site in the study; it needs to be clearly on the other side of the line the study drew.

What the intake must ask about

A GLP-1 contraindications intake questionnaire is shorter than most brands expect. The categories below are the ones product labels and standard prescribing references flag, described in plain words. The wording of each question, the scoring and the decision rule belong to the medical director. The operator's job is to make sure the intake questionnaire covers every category and that a flagged answer routes to a provider rather than to a checkout page.

• Personal or family history of medullary thyroid carcinoma, or of the inherited condition multiple endocrine neoplasia type 2. Product labels for the injectable GLP-1 medications carry a boxed warning on this point, and it is the one question a reviewer will look for first.
• History of pancreatitis.
• Pregnancy, plans to become pregnant, or breastfeeding.
• History of an eating disorder, including current purging or restriction. This is the question about half the sites in the JAMA study skipped.
• Type 1 diabetes, and any history of diabetic ketoacidosis.
• Current use of insulin or a sulfonylurea, because of the risk of low blood sugar when a GLP-1 is added.
• Gallbladder disease.
• Severe gastrointestinal disease, including gastroparesis.
• Diabetic retinopathy, for patients with diabetes.
• Kidney disease.
• History of bariatric surgery.
• Current or recent depression, suicidal thoughts or psychiatric treatment.
• Whether the patient is already on a GLP-1 from another prescriber, and every other current medication, supplement and allergy.
• Age, and a current height and weight with the method of measurement recorded.

Two things about this list matter for the operator. Several items are relative rather than absolute, meaning the provider may prescribe with extra monitoring or a documented reason. The platform has to let a provider prescribe against a yellow flag and record why, and it has to stop a prescription against a red flag. And the eating-disorder and mental-health questions are the ones the study caught sites skipping, which also makes them the ones most likely to be raised in a complaint. They go in.

The intake should also verify identity and location. The patient's state at the time of the visit decides which license the provider needs, and a photo identity check plus a stated address is the minimum. Weight verification deserves its own line: if the protocol asks for a full-body or scale photo, the reviewer must actually check it. A rule that exists on the website but not in practice is worse than no rule, because it documents that the brand knew what the standard was and did not meet it.

Labs: when required, when optional

The question of telehealth GLP-1 without labs is where the standard is least settled and where brands most often overcorrect. A blanket lab requirement before any prescription adds days and cost and loses a share of patients who would have been fine. No lab requirement at all is what the study's harshest findings describe. The defensible position is a written lab policy the medical director signs, with three tiers.

• Labs required before prescribing when the intake flags something a lab can settle: a diabetes history without a recent A1c, a kidney or liver history, symptoms that suggest thyroid disease, or a stated weight that sits close to the eligibility threshold.
• Labs ordered at or shortly after the first prescription for everyone else, with a defined window in which results must be reviewed and a rule for what happens if they are not returned.
• Labs on a schedule during treatment, tied to the titration steps or to a fixed interval the medical director sets, with the result reviewed and the review documented.

The panel itself is the provider's call. A common baseline includes a metabolic panel, an A1c and a lipid panel, with thyroid and other tests added on indication; the medical director decides, and the operator should not. What the operator does decide is whether lab ordering is built into the platform or handled by a patient carrying a paper requisition to a draw site, because the second version produces a large share of patients who never get the draw done. Lab ordering with results flowing back to the chart, and a task to the provider when a result is out of range, is the operational half of the lab policy.

Titration and follow-up cadence

The titration protocol is the dose schedule the provider follows over the first months. The manufacturer labels define a schedule for the branded products, and the medical director writes the protocol for a program, including how to handle a patient who cannot tolerate a step. No part of it is the operator's to write, and this post gives no dosing.

What the operator does own is the follow-up cadence, which is a scheduling and platform question. A defensible cadence looks like this: a check-in within the first two weeks of the first dose, a provider touchpoint before each dose increase with a documented decision to step, hold or reduce, a synchronous visit or at least a provider-reviewed asynchronous exchange at a fixed interval the medical director sets, and a route by which a reported side effect reaches a licensed person within a defined time. The cadence should be enforced by the platform, meaning the next shipment and the next dose step cannot proceed until the check-in has happened and a provider has signed it.

This is the piece the JAMA study found missing most often: sites where a prescription was issued and the next contact was a rebill. Asynchronous care, where the patient answers questions and a provider reviews them later, is permitted in most states for a non-controlled medication and is how most GLP-1 telehealth runs. The word that matters is reviewed. A standard of care argument is won or lost on whether a licensed person made a decision at each point where a decision was due.

Documentation that shows the standard was met

Documentation is what turns a good protocol into a defense. If a complaint arrives eighteen months later, the chart is the only witness. The following should exist for every patient, in the record, generated by the platform rather than reconstructed later.

• The completed intake questionnaire with timestamps, the patient's identity and location verification, and the photos or measurements the protocol required.
• A provider note for the initial encounter that records the eligibility finding, the contraindication review, the lab decision and the reasoning, signed by a provider licensed in the patient's state.
• Informed consent specific to the medication, covering the boxed warning, the common side effects and what to do if they occur, with the patient's acknowledgement recorded.
• A note for every dose step, hold or reduction, with the patient's report and the provider's decision.
• Lab orders, results, the date reviewed and by whom.
• Every patient message about a symptom and the reply, with the time between them visible.
• The patient-provider relationship record: who the treating provider is, when the relationship was established, and any handoff between providers.

Two specifics deserve attention. The first is the patient-specific order. Whatever else the record shows, it must show that a named provider made a decision about this patient, on this date, for this reason. A prescription that looks like the output of a form is exactly what the study described and what a board investigator looks for. The second is state licensure matching: the provider who signs must hold a license in the state the patient was in during the visit, and the record should make that match visible without a lookup. GLP-1 medications are not controlled substances, so the DEA's telemedicine rules and EPCS, the electronic prescribing standard for controlled substances, do not apply to them. That removes one set of requirements; it does not remove the state ones.

How screening changes conversion, and why it is worth it

Every question added to an intake costs completions, and operators who have run a funnel know the number by heart. The list above is longer than a five-question form and shorter than a new-patient packet. The realistic position is that a defensible intake will convert lower than a checkout-style one, and that the brands the JAMA study described chose the higher conversion.

The trade is worth it on three counts that show up in the numbers rather than in principle. A properly screened patient is more likely to still be a patient at month three, because side effects were anticipated and titration was handled rather than scheduled. A brand with a documented protocol can answer a board inquiry, a payment processor's risk review or a LegitScript application with a file rather than a scramble; LegitScript certification, which Google, Meta, Microsoft and TikTok recognize for prescription-drug advertising according to LegitScript's own certification page, asks for exactly this kind of documentation. And the malpractice and board exposure of an unscreened program does not show up until the first claim, at which point it is the whole business. A protocol is the cheapest insurance a brand can buy, and it is one the brand's own providers will insist on if they are any good.

Conversion can be recovered elsewhere. Splitting the intake so that the fast disqualifiers come first, showing progress, and letting the patient book the provider touchpoint before finishing the form all reduce abandonment without dropping a question.

A brand does not need to be the strictest site in the study; it needs to be clearly on the other side of the line the study drew.

Questions operators ask

Does a brand need a video visit for every patient? Most states allow an asynchronous first encounter for a non-controlled medication, and the state pages on this site cover the exceptions. The defensible position is that the medical director decides which patients need a synchronous visit, that the platform can schedule one when a flag is raised, and that the decision is recorded.

Can the operator write the protocol and have a provider sign it? The protocol has to be the provider's, and in a state with a corporate practice of medicine rule the operator, as a management company, cannot direct clinical decisions at all. The operator can hire the medical director, pay for the platform that enforces the protocol, and insist that one exists.

Can screening be handled by an outside clinical operation? It can, and this is how most brands run. Tessic Health's licensed physicians and nurse practitioners in all 50 states own the intake, the lab policy and the titration protocol for a client brand's weight loss program, and the platform enforces the follow-up cadence and generates the documentation described above. The weight loss launch page describes the setup. A brand that builds its own clinical operation needs the same pieces; the list in this post is the list either way.

What should be done about a program that is already running without most of this? Pause new enrollments for the time it takes the medical director to write the protocol, re-screen active patients at their next check-in, and start documenting from the next visit. A protocol adopted mid-stream is a defense; a protocol that never existed is the study's headline.