Avoid account freezes, chargebacks, and compliance headaches with this step-by-step guide.
As weight loss medications like semaglutide and tirzepatide rise in popularity, more clinics are offering them — often as part of cash-pay or concierge programs. But with this opportunity comes new scrutiny: from regulators, from pharmacies, and critically, from your payment processor.
Being careful in what you publish, and where, is critical to staying compliant and avoiding refund disputes, account holds, or even termination.
Here's how to stay on solid ground while offering these services — especially if you’re accepting payments online.
- Remaining compliant with payment processors
- Picking a compliant business model
- Tracking the requisite information in your EMR
Why Payment Processors Care About Weight Loss Programs
Weight loss services — particularly when they include prescription medications — are often considered high-risk. Why?
- High volume of chargebacks and refunds
- Off-label or compounded medication concerns
- Claims of guaranteed results
- Association with beauty/supplement industries
- Potential state or FDA scrutiny
Even if your clinic is fully compliant and physician-led, your payment processor’s risk team doesn’t know that at first glance. That’s why being proactive is key.
What You Must Do to Stay Compliant
Be Transparent About What You’re Selling
Use clear, itemized service descriptions. Avoid vague terms like “monthly plan” or “premium service” unless you specify what’s included. Instead, try:
- Initial medical consultation (with licensed provider)
- 1-month compounded semaglutide (Rx-only, pharmacy-fulfilled)
- Weekly injection support and ongoing coaching
Post Clear Terms and Refund Policies
You should have:
- Signed consent forms for treatment, risks, and limitations
- A no-refund policy or refund terms clearly outlined and signed
- Medical disclaimers on your site and invoices
- Documentation that matches what patients were charged for
This protects you from chargebacks — and helps satisfy PCI and card brand rules.
What Not to Say on Your Website
Certain language is a red flag — not just to processors, but to regulatory agencies as well.
Avoid:
- “Guaranteed results”
- “Lose 15 pounds in 30 days!”
- Mentioning specific drug names (especially if compounded or off-label) like “semaglutide” or “tirzepatide” without full medical context
- Statements implying everyone qualifies or will receive medications
Use instead:
“This is a medically guided weight loss program. Medication may be prescribed based on clinical appropriateness. Individual results vary.”
Also, do not show before/after photos without consent and proper disclaimers (e.g., “Individual results may vary. This image is for illustrative purposes only.”)
Choosing the Right MCC (Merchant Category Code)
Use an MCC that matches your clinical services. For example:
- 8099 – Medical services (general)
- 8011 – Doctors and physicians
- 8049 – Health practitioners not elsewhere classified
Avoid codes related to:
- Weight loss products
- Cosmetics or supplements
- Online retail or general e-commerce
Misclassifying your business can get your account flagged or terminated.
Shipping Medications: Two Legal & Compliant Models
Shipping Rx meds requires both regulatory and payment processor compliance. Here are the two compliant options:
Option 1: Patient Pays the Pharmacy Directly (Preferred)
- You bill only for your clinical services (consult, coaching, program access)
- The pharmacy charges the patient directly for the medication
- This keeps you out of the “drug reseller” risk category with your processor
Most processors — including Fiserv and Stripe — require this model.
Option 2: You Collect Payment, Pharmacy Ships
- You charge the patient for a bundled program (consult + meds)
- The medication is drop-shipped from a licensed pharmacy
- You must clearly document the prescription and fulfillment process
- Your payment processor may ask for proof that the consult occurred before payment and that the med is legally dispensed
If you use this model, expect increased scrutiny — and make sure:
- Meds aren’t shipped without Rx authorization
- Your EMR logs consultation and authorization details
- You don’t ship from in-house inventory unless you’re a licensed pharmacy
Tracking Best Practices in Your Weight Loss EMR to Reduce Risk
- Ensure all practice policies and consents are collected and signed digitally (intake, consent, financial)
- Track patient IDs like driver’s licenses
- Take comprehensive visit notes that include a log of consultation timestamps and outcomes in your EMR
- Use built-in e-prescribing (eRx) to track patient prescriptions and refill requests
- Use Superbills and itemized invoices to match payment records
- Provide clear customer support contact info for questions/refunds
- Train your team to respond quickly to payment disputes or chargebacks to minimize your losses
Don’t Wait Until You're Frozen -
Make These Decisions Before Offering Your Next Weight Loss Offering - Go Back And Edit Your Website Now
Processors are cracking down on clinics that don’t follow these rules. We’ve seen accounts get frozen overnight — not because of wrongdoing, but because of vague websites, unclear billing, or misleading marketing.
When in doubt, simplify:
- Bill clearly
- Prescribe responsibly
- Document everything
- Use a compliant EMR and billing system
Need Help?
If you're switching EMRs or offering weight loss services, make sure your billing workflows, website, and provider documentation are all aligned. Our team works with PCI-compliant processors and can help you:
- Structure your weight loss programs
- Set up legal and transparent billing
- Train staff on compliant workflows
Schedule a demo before launching your next weight loss program.
