The short answer
Charge after a clinician approves treatment, refund everything that has not been dispensed, and say plainly that dispensed medication cannot be returned. Those three rules answer most refund questions a subscription brand will get. The rest is mechanics: an online cancel button, a reminder before every renewal, and a refund issued before the patient calls their bank.
The reason the dispensed-medication rule exists is regulatory, and it is older than telehealth. Michigan's pharmacy rules say prescription drugs that "have been dispensed and have left the control of the pharmacist" must not be returned or exchanged for resale (Mich. Admin. Code R 338.503). Ohio allows return to stock only for drugs that never left the pharmacy or its delivery agent (Ohio Admin. Code 4729:5-5-22). FDA's long-standing compliance policy guide says a pharmacist should not return drugs to stock once they have been out of the pharmacy's control (CPG Sec. 460.300). States differ in the details, and a few allow narrow exceptions, but in practice a pharmacy will not take back a shipped GLP-1 pen so that you can refund it. Your policy has to say so before the patient pays.
This is not legal advice; have a lawyer licensed in your states review the final text.
What is refundable at each stage
| Stage | What the patient has been charged | What we would refund |
|---|---|---|
| Intake submitted, not yet reviewed | Nothing; card authorized only | Void the authorization if they withdraw |
| Clinician declines treatment | Nothing | Nothing to refund; the authorization lapses |
| Approved, pharmacy has not filled | First cycle captured | Everything, care fee included |
| Filled and shipped | First cycle | No refund for medication; care fee only if shipping failed |
| Shipment lost, damaged, or arrived warm | First cycle | Reship at no cost or refund in full, patient's choice |
| Renewal charged, not yet dispensed | Renewal | Everything, if they cancel before the fill |
| Renewal charged and dispensed | Renewal | Nothing for that cycle; cancellation stops the next one |
| Membership or care fee mid-period | Current period | No proration; access runs to the end of the period |
Two rows deserve a comment.
The third row is a position, and some operators will disagree. The clinician did real work reviewing the case, and keeping the consult fee when a patient changes their mind before the fill is defensible. We would still refund it. A disputed charge costs the merchant $8 under Visa's acquirer monitoring program once enrolled, plus the chargeback itself, plus a mark against a ratio that tips into "excessive" at 1.5% of card-not-present transactions in a month (the VAMP post has the math). A 500-transaction program reaches that line at seven disputes. Refunding a first-cycle consult fee is cheap insurance.
The lost-shipment row matters more for GLP-1 programs than anything else on the list, because cold-chain products that arrive warm are both a safety issue and the most common "not received" or "not as described" dispute. Decide in advance whether the pharmacy or the brand eats the cost of a reship, and put it in the pharmacy agreement.
When the charge happens decides most of this
If the card is captured at intake, the first three rows of the table turn into refunds, and every refund is a chance for a dispute. If the card is authorized at checkout and captured when the clinician approves, the first two rows cost nothing. Charging at intake submission, before any provider review, is the first allegation in the FTC's July 29, 2026 complaint against Hims & Hers (Hims denies it and is fighting the case). We covered the design in the checkout spec; the refund policy is the written version of the same rule.
Authorizations expire after a window set by the card network. If review sometimes runs longer (labs, a required video visit), the billing system has to re-authorize against the stored card, and the policy wording "charged when your clinician approves treatment" stays true either way.
Cancellation: online, one step, in writing
The federal floor is the Restore Online Shoppers' Confidence Act: clear disclosure of material terms before taking billing information, express informed consent, and "simple mechanisms" to stop recurring charges (15 U.S.C. § 8403). The FTC's 2024 click-to-cancel amendments were vacated by the Eighth Circuit on July 8, 2025, and the Commission reopened the negative option rulemaking with an advance notice in March 2026; no new rule exists yet. ROSCA did not go anywhere, and the FTC keeps bringing cases under it.
California is the stricter practical standard because most brands serve California patients. Under Business and Professions Code § 17602, a consumer who signed up online must be able to cancel "exclusively online, at will," through a prominent link or button. A retention offer is allowed, but only alongside a prominently displayed cancel option, and it cannot obstruct cancellation (§ 17602). The AB 2863 amendments, effective July 1, 2025, added an annual reminder of the terms and a separate express consent to the auto-renewal (Barnes & Thornburg).
So the working spec: a cancel button on the account page that completes without a call or chat. A pause or dose-change option can sit on the same screen. An email confirming the effective date and the last charge. And one telehealth-specific sentence: if a refill has already gone to the pharmacy, say so on the cancel screen and offer to stop it if it has not been filled.
Renewal reminders
Send one before every renewal, not only the ones the law requires. California requires a notice 3 to 21 days before a free trial or promotional price ends when that period runs longer than 31 days. Visa's rules for free trials and introductory offers, in force since April 18, 2020, require merchants to remind the cardholder with a cancellation link before the first full-price charge (Visa). For an ordinary monthly program, three days before the charge by email and text, with the amount, the date, and a one-tap link to pause or cancel, is what we would ship.
Reminders do cause some cancellations. They move them to before the charge, the cheapest place for one to happen. What patients need to see before the first renewal covers the screen-level detail.
Policy text you can adapt
Written as plain policy. Change the time windows to match your operations, and have counsel review it for every state you serve.
Refund and Cancellation Policy
When you are charged. When you complete checkout, the Company verifies your payment method but does not charge it. Your clinician reviews your intake. You are charged only if your clinician approves treatment. If your clinician does not approve treatment, you are not charged.
Your subscription. Your plan renews automatically at the price and interval shown at checkout until you cancel. The Company sends a reminder by email and text at least three days before each renewal charge, with the amount, the date, and a link to cancel or pause.
Cancelling. You can cancel at any time from your account page without calling or writing to us. Cancellation stops all future charges. You will receive an email confirming your cancellation, its effective date, and your final charge. If a refill is already with the pharmacy, the cancellation screen will tell you whether it can still be stopped.
Refunds before your medication is dispensed. If you cancel after being charged but before the pharmacy has filled your prescription, the Company refunds the full charge for that cycle to your original payment method.
Dispensed medication. Pharmacy laws generally do not allow a pharmacy to accept returns of prescription medication once it has been dispensed. For that reason, charges for medication that has been dispensed are not refundable, and the Company cannot accept returned medication. Please do not mail medication back to the Company or the pharmacy.
Shipping problems. If your order is lost, arrives damaged, or arrives outside the temperature range stated on the package, contact the Company within seven days of the delivery date shown in your tracking. The Company will reship your order at no cost or refund it in full, at your choice.
Membership fees. Membership and care fees cover a billing period and are not prorated. If you cancel during a period, your access continues until the period ends.
How refunds are paid. Refunds go to your original payment method within five business days of approval. Your bank may take additional time to post them.
Questions about a charge. Contact the Company through your account or by email before contacting your bank.
The last paragraph is there for your dispute ratio. A refund issued before the cardholder files closes the matter; a refund issued after the dispute does not remove it from the month's count.
Where the platform fits
The policy is only as good as the billing behind it. "Refund everything not yet dispensed" requires billing that knows the pharmacy's fill status, and one-step cancellation requires a portal that owns the subscription.
Turbopills runs these on one system: the subscription starts when the provider approves, refunds are one click from the admin console, failed renewals retry automatically, and order status and cancellation live in the patient portal. The policy wording, the time windows, and the decision on who pays for a warm shipment stay with you and your counsel. We are in private beta; in a demo, ask us to run a decline, a cancel before the fill, and a refund end to end.
FAQ
Can a telehealth company refuse refunds on prescription medication? Yes, for medication that has been dispensed, and the policy should say why: state pharmacy rules and FDA guidance generally bar pharmacies from returning dispensed drugs to stock. Undispensed orders should be refunded in full.
Do I have to let patients cancel online? Under California's auto-renewal law, a patient who signed up online must be able to cancel online, at will, with a prominent link or button. ROSCA requires a simple cancellation mechanism nationwide. Building the California version everywhere is the simplest choice.
Should I charge before or after the provider approves? After. Authorize the card at checkout and capture on clinical approval. A declined patient then has nothing to dispute, and you avoid the fact pattern in the FTC's complaint against Hims & Hers.
How do refunds affect chargebacks? A refund issued before the patient disputes the charge closes it. After a dispute is filed, a refund does not remove it from your Visa ratio, so fast refunds matter more than generous ones. More on the dispute side in reducing refunds and chargebacks.