Controlled Substance Policy
This policy is a template pending review by counsel.
Welm Health, LLC (“Welm”) is a telehealth platform focused on longevity and metabolic care. This Controlled Substance Policy explains how Welm and the licensed providers who use our platform approach the prescribing of medications, with particular attention to any medication that is or may become a federally controlled substance. Our goal is safe, lawful, and clinically appropriate care.
Compliance With Federal Law
Welm and its providers comply with the federal Controlled Substances Act (CSA) and the Ryan Haight Online Pharmacy Consumer Protection Act. These laws govern how controlled medications may be prescribed, dispensed, and delivered, including in the context of telemedicine. We structure our clinical workflows to meet these requirements and to adapt as federal rules evolve.
Provider-Patient Relationship
A legitimate provider-patient relationship is required before any prescription is issued. No medication is prescribed based on an online form alone. A licensed provider must review the patient’s health history, evaluate clinical appropriateness, and, where required by law, conduct an examination consistent with applicable telemedicine standards.
Identity and Residency Verification
- We verify each patient’s identity before care is provided.
- We verify the patient’s state of residence, because prescribing authority depends on where the patient is physically located.
- Care is provided only where the treating provider holds the appropriate license.
Welm’s Current Catalog
The medications and therapies in Welm’s current catalog, including GLP-1 therapies, peptides such as Sermorelin, NAD+, MICC, and vitamin B12, are generally not federally scheduled controlled substances. If a provider determines that a controlled medication is clinically appropriate for a given patient, that prescription would follow the stricter rules that apply to controlled substances under federal and state law, including any additional evaluation, documentation, and dispensing requirements.
Refills and Dose Changes
To protect patient safety, Welm does not permit early refills or dose escalation without documented clinical review. A provider must evaluate the patient’s response, tolerance, and continued appropriateness before authorizing any change. Requests that fall outside safe clinical parameters will be declined.
State-by-State Variation
Telemedicine prescribing law varies significantly from state to state. Some states impose additional requirements on the establishment of the provider-patient relationship, the types of visits that qualify, and the prescribing of specific medications. Welm’s providers follow the law of the state in which the patient is located, and availability of certain treatments may differ by state.
Licensed Pharmacy Partners
Prescriptions are filled by licensed pharmacy partners, including compounding and dispensing pharmacies where appropriate. These partners are responsible for pharmacy-level compliance, verification, and safe dispensing and shipping in accordance with applicable law.
Suspected Misuse or Diversion
Welm takes suspected misuse, abuse, or diversion seriously. Warning signs may include requests for early refills, inconsistent histories, or patterns suggesting non-therapeutic use. In such cases, a provider may decline to prescribe, discontinue treatment, or terminate the care relationship. Where mandated reporting is required by law, Welm and its providers will comply. We may also decline service to protect patient safety and the integrity of our platform.
Contact
Questions about this policy may be directed to [email protected].