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Direct-to-consumer telehealth brands

What a certification review looks for in an ED and men's health brand

Men's health brands are certified routinely, but ED and hair-loss categories draw a closer review of three things in particular: whether a genuine prescribing decision happens, whether the product is described accurately, and whether a subscription can actually be cancelled.

By VeriScripts · · 5 min read

Erectile dysfunction and men's health were the first mass direct-to-consumer telehealth categories and they set the template the rest of the industry copied: a quiz, an asynchronous review, a subscription, discreet packaging. They also accumulated the enforcement history that shaped how these models are now read.

The category is certified routinely. It simply gets read more carefully, and it is worth knowing where the attention goes.

Is there a real prescribing decision

The defining question for the category. An asynchronous model, where a patient completes an intake and a licensed prescriber reviews it without a live consultation, is workable where the states you operate in permit it. What is not workable is a model where the prescribing decision is functionally automatic.

A reviewer probes this in a few ways. Does the intake screen for the contraindications the medicine actually has, cardiac history and nitrate use among them? Can a prescriber decline, and does that visibly happen? Is the prescriber licensed in the patient's state? Is there a route back to a clinician if something goes wrong?

The marketing copy is read as evidence about this. A funnel that promises the medicine before anyone has reviewed anything is describing an automatic decision, whatever the clinical workflow behind it actually does.

Is the product described accurately

Men's health brands sell across three quite different product types and the claims rules differ for each.

Approved products, prescribed generically. The most straightforward case. The product is what it is and the approved labelling exists.

Compounded preparations. Combination products, alternative delivery formats, chewables and troches. These are compounded, they are not approved products, and they may not be described as though they are. Everything in the compounded marketing rules applies here too, because the underlying issue is identical.

Supplements sold alongside medicines. The category's quiet risk. Structure and function claims for a supplement sold next to a prescription product, in the same cart, under the same brand, tend to read as disease claims by association. Keeping the two clearly separated in the shop and in the copy is worth doing before somebody asks.

Can the subscription be cancelled

This is where men's health brands attract the most consumer-side attention, and a reviewer knows it.

The specific defects that come up: renewal terms disclosed only after purchase, cancellation available only by telephone during limited hours, a cancellation flow that offers three retention screens before the button, and a card descriptor that customers do not recognise, which converts a cancellation into a chargeback.

Fixing these is not a concession. Cancellation friction in this category generates chargebacks, and chargeback exposure is part of what your acquiring bank is underwriting, so the fix improves two problems at once.

The privacy dimension is sharper here

Men's health carries a stigma that patients are acutely aware of, and the disclosure expectations follow.

Discreet packaging should be described honestly rather than implied. What appears on the card statement should be stated before purchase. The tracking on an intake flow where a patient answers questions about sexual health deserves a harder look than the same tracking on a general wellness site, because the data is more sensitive and the consequences of leaking it are worse.

And the document distinction still applies: a website privacy policy is not a Notice of Privacy Practices, and a covered entity needs both.

The testimonial problem

This category runs on social proof, and social proof here is claim material. A testimonial that describes a result is an effectiveness claim about the product the customer received, which for a compounded preparation is a claim nobody has evidence for. An influencer comparing your product to the brand-name drug has made a comparison claim on your funnel.

Supply your affiliates with the allowlist. Read your own review widget. Both are part of the marketing surface a reviewer will see.

Where brands in this category usually stand

Better than they fear on the clinical model and worse than they think on the funnel. The prescribers are real, the pharmacy relationship is documented, and the copy on the landing page was written to a conversion brief by somebody who had never been given the rules.

That is a fixable position, and it is fixable before submission rather than during a review, which is the difference between a short review and a rework loop.

An audit specific to this category

Run these six checks on your own funnel before anybody else does.

  • Open the quiz as a patient. Does it screen for cardiac history and nitrate use, and does it read as an assessment or as a checkout step?
  • Read the result screen. Does it name a product before a prescriber has reviewed anything, and does it use the word personalised about something that is not?
  • Find the cancellation path without using search. Count the clicks and the retention screens.
  • Check the descriptor that appears on a card statement, and check that it is disclosed before purchase.
  • Read your review widget. How many testimonials state a result, and for which products?
  • Look at your shop. Are supplements visually and commercially separated from prescription products, or do they share a cart, a bundle and a claim?

Where the category is heading

The models that were novel five years ago are now the default, and the scrutiny has moved from whether asynchronous care is acceptable to whether a particular implementation of it is genuine. That is a better question and it favours operators who can document their clinical workflow.

The practical implication is that the documentation which makes an application straightforward, the intake logic, the contraindication screening, the decline rate, the supervision structure, is the same documentation that will answer the next platform policy change and the next acquirer questionnaire. It is worth writing down properly once, rather than reconstructing it each time somebody asks.

Frequently asked questions

Is an asynchronous intake model acceptable?

It is workable where the states you operate in permit it and where the model is described accurately. What draws scrutiny is a funnel that promises the medicine before any clinical review, because that describes an automatic decision regardless of what the workflow behind it does.

Can I sell supplements alongside prescription products?

Yes, but keep them clearly separated in the shop and in the copy. Structure and function claims for a supplement sold in the same cart as a prescription medicine tend to read as disease claims by association.

Do customer testimonials need to be removed?

Not removed, but read as claims. A testimonial stating a result is an effectiveness claim about the product that customer received, which for a compounded preparation is a claim without supporting review behind it.

General compliance information, not legal or medical advice.