A telehealth launch has thirteen phases, and the order matters more than the speed: pick the offer, form the operating company and open banking, sign the MSO and professional-entity agreements, onboard to the platform, lock brand and pricing, configure the storefront and app, design intake with the clinical team, set up pharmacy routing and lab panels, file LegitScript, connect payments and subscriptions, open ad accounts and place pixels correctly, write support playbooks, run a soft launch against a short list of metrics, and go live. On white-label infrastructure, the clinical, pharmacy, lab and compliance items are already built, so the founder's list shrinks to company, brand, offer, marketing and support. This page is the item-by-item version of that list, with an owner column for every line so nothing sits between two desks.
For the week-by-week view of the same work, read the telehealth launch timeline. For who is allowed to own the company, read how to start a virtual clinic. This is general information, not legal or medical advice.
Key takeaways
- The gating items in a telehealth launch are the entity and MSO agreements, provider coverage in every launch state, pharmacy licensing in those states, and LegitScript certification; everything else can run in parallel.
- Every checklist line needs one owner. On MyOrbitHealth the split is simple: you own company, brand, offer, marketing and non-clinical support; MyOrbitHealth owns providers, intake engine, e-prescribing, pharmacy, labs, compliance infrastructure and the LegitScript filing.
- File LegitScript as soon as the entity, policies and pharmacy relationships exist, because certification sets the date you can run paid ads, not the date you can see patients.
- Keep advertising pixels off pages that collect health information and sign a BAA with every vendor that touches PHI before the first patient arrives.
- A soft launch with a small, controlled audience exposes intake drop-off, routing gaps, shipping delays and support load before paid traffic amplifies them.
Who this is for
- Founders and operators launching a cash-pay telehealth brand in GLP-1, hormones, sexual health, hair, skin, women's health or wellness.
- Med spa and clinic owners adding a virtual program and wanting a single list of what has to be done and by whom.
- Supplement, creator and e-commerce brands upgrading to prescription offers on DTC brand infrastructure.
How should you read this telehealth launch checklist?
Each phase below is a table. The first column is the checkbox, the second is the item, the third is the owner, and the fourth is the definition of done. "You" means the brand's team; "MyOrbitHealth" means the platform and the licensed clinical and pharmacy layer behind it; "Both" means a joint working session. Phases 1 through 3 gate everything else. Phases 4 through 11 can run in parallel once the platform kickoff has happened. Phases 12 and 13 close the launch.
Phase 0: What offer are you launching?
Decide this before any paperwork, because it determines the states, the modality, the pharmacy and the lab panels.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Pick the launch vertical (one, not four) | You | A single hero program is named, e.g. GLP-1 weight loss or TRT |
| ☐ | Pick launch states | You | A state list exists, checked for each vertical's legality |
| ☐ | Confirm vertical and states are supported | MyOrbitHealth | Scope confirmed at onboarding for verticals, states and volume |
| ☐ | Choose modality per condition | Both | Async, video or hybrid is set per program; controlled substances mapped to video |
| ☐ | Draft the retail price and plan structure | You | Monthly or quarterly plan, what is included, refill cadence |
| ☐ | Model the budget | You | Directional ranges run through the startup cost calculator |
Phase 1: Entity and banking
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Form the operating company (MSO) | You | Articles filed in your home state; operating agreement signed |
| ☐ | Obtain EIN | You | IRS letter on file |
| ☐ | Open a business bank account | You | Account funded; signatories set |
| ☐ | Register the DBA and buy the domain | You | Brand name and domain secured; trademark search done, filing started |
| ☐ | Apply for a merchant account | You | Processor underwriting started with telehealth disclosed as the business type |
| ☐ | Confirm merchant-of-record position | MyOrbitHealth | Written confirmation that your company is merchant of record and owns patient data |
Merchant underwriting can take longer for telehealth than for ordinary e-commerce. Start it in week one, and be accurate about what you sell.
Phase 2: MSO and professional-entity agreements
If you are not a licensed clinician, a physician-owned professional entity delivers the care and your company provides everything non-clinical under a management services agreement. On MyOrbitHealth the licensed clinical layer operates under an MSO / friendly-PC structure; your counsel still reviews how your company plugs into it for your states.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Engage healthcare counsel for launch states | You | Engagement letter signed; CPOM review scoped per state |
| ☐ | Management services agreement reviewed | Both | MSA terms (services, fees, control, data ownership, exit) approved by counsel |
| ☐ | Business associate agreement executed | MyOrbitHealth | BAA signed; it is in every MyOrbitHealth contract |
| ☐ | Telehealth consent language approved | Both | Consent text meets each launch state's requirement and is captured in intake |
| ☐ | Privacy policy, terms and Notice of Privacy Practices published | You | Documents describe what the site actually does with health data |
| ☐ | Platform agreement signed | Both | Flat platform fee scoped; 0% medication markup, no revenue share, no exit fee, month-to-month after onboarding confirmed in writing |
The guide to starting a telehealth business without a medical license explains the structure in detail.
Phase 3: Platform onboarding
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Kickoff call held | Both | Verticals, states, volume, modality and launch date agreed |
| ☐ | Tenant provisioned in OrbitOS | MyOrbitHealth | Your brand exists in the clinical console with role-based access set |
| ☐ | Team accounts and roles issued | Both | Named users for ops, support, marketing; least-privilege roles |
| ☐ | Provider routing configured for launch states | MyOrbitHealth | Patients in every launch state route to a licensed provider from the 2,400+ network |
| ☐ | Bring-your-own providers credentialed (if any) | Both | Your clinicians pass NCQA-standard primary-source credentialing and OIG/SAM screening |
| ☐ | API sandbox keys issued (if integrating) | MyOrbitHealth | Test keys for https://api.myorbithealth.com/v1, provisioned within a day after partner review |
| ☐ | Webhook endpoints registered (if integrating) | You | Signed webhooks received for appointment.completed and prescription.dispensed in sandbox |
Hosted-clinic brands skip the last two lines.
Phase 4: Brand and offer
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Logo, colors, type and tone guide | You | Assets delivered in the formats the storefront and app need |
| ☐ | Program names and descriptions | You | Each program has a name, who it is for, what is included, what is excluded |
| ☐ | Claims review of all copy | Both | No efficacy or outcome claims that cannot be substantiated; no drug-name promotion in ads where platform policy prohibits it |
| ☐ | Pricing and plan design final | You | Price, billing cadence, cancellation terms and refund policy written down |
| ☐ | Email and SMS templates branded | You | Welcome, order, shipping, refill and check-in messages carry your brand |
Plan design has more effect on retention than any ad. The telehealth subscription pricing guide covers cadence, bundling and failed-payment recovery.
Phase 5: Storefront and app
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Storefront configured on your domain | Both | Programs, prices and checkout live under your brand |
| ☐ | Patient portal branded | MyOrbitHealth | Messaging, refills, orders and results live in the white-label patient portal |
| ☐ | Native iOS/Android app submitted (if using) | Both | White-label app built and submitted to the app stores under your developer accounts |
| ☐ | Subscription products created | You | Each plan maps to a subscription with the right cadence |
| ☐ | Legal pages linked from footer | You | Privacy, terms, consent, NPP, and refund policy reachable from every page |
| ☐ | Accessibility and mobile checks | You | Checkout and intake complete on a phone without horizontal scroll or dead ends |
Phase 6: Intake design with the clinical team
Intake is the front door and the first clinical control. Orbit Intake supplies the adaptive engine with severity scoring and red-flag escalation; the clinical team sets the questions and thresholds per program; you set the tone and the brand.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Intake questionnaire per program reviewed | MyOrbitHealth | Clinical team approves questions, contraindication logic and red flags |
| ☐ | Identity verification step configured | MyOrbitHealth | Patient identity is verified before provider review; fallback path defined |
| ☐ | Photo and document requirements set | Both | Only what the protocol needs (e.g. ID, relevant photos), nothing more |
| ☐ | Consent capture embedded | Both | Telehealth consent, privacy acknowledgment and terms accepted inside intake with timestamps |
| ☐ | Red-flag outcomes mapped | MyOrbitHealth | Severe answers route to escalation or decline, with patient-facing language approved |
| ☐ | Decline and alternative paths written | You | Patients who are not candidates get a clear, respectful message and next step |
The telehealth patient journey post shows where intake sits in the full flow and where drop-off usually happens.
Phase 7: Pharmacy and lab setup
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Formulary per program agreed | Both | Medications, strengths and forms listed; compounded vs retail noted |
| ☐ | Pharmacy routing by state confirmed | MyOrbitHealth | Each launch state maps to a LegitScript-certified pharmacy licensed to ship there |
| ☐ | Cold-chain process confirmed | MyOrbitHealth | Injectables ship cold-chain to all 50 states with tracking |
| ☐ | Medication cost pass-through confirmed | MyOrbitHealth | 0% markup stated in the agreement; cost sheet reviewed |
| ☐ | Test prescription end to end | Both | A test script moves from OrbitRx through Surescripts to the pharmacy and returns a tracking event |
| ☐ | EPCS readiness (if controlled substances) | MyOrbitHealth | Two-factor identity proofing in place for prescribers; DEA-registered partner pharmacies mapped |
| ☐ | Lab panels per program configured | Both | Orbit Labs panels set; draw options chosen (Quest/Labcorp walk-in, Tasso at-home kit, mobile phlebotomy) |
| ☐ | Self-order lab catalog decided | You | Which panels appear on the storefront; every order still signed by a provider |
Lab pricing is quoted per program during onboarding. See the labs page for the three draw methods.
Phase 8: LegitScript filing
Google's healthcare and medicines policy requires telemedicine advertisers in the United States to be certified by LegitScript and then approved by Google; Meta and Microsoft recognize the same certification. File as soon as the entity, policies and pharmacy relationships exist.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Document pack assembled | Both | Entity records, licenses, DEA certificates where applicable, privacy policy, prescribing policies, pharmacy relationships, planned ads |
| ☐ | Website matches the application | You | Live site shows the same programs, disclosures and policies the filing describes |
| ☐ | Application prepared and filed | MyOrbitHealth | Filed under your brand; MyOrbitHealth manages questions through approval |
| ☐ | Certification fees budgeted | You | Application and annual fees per website, as published by LegitScript, in the budget |
| ☐ | Approval received | MyOrbitHealth | Certificate issued; typically days once filed, never guaranteed |
The LegitScript certification guide covers the nine standards reviewers check.
Phase 9: Payments and subscriptions
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Merchant account approved and connected | You | Live transactions settle to your bank; you are merchant of record |
| ☐ | Subscription billing tested | Both | Initial charge, renewal, upgrade, pause and cancel all tested with a test card |
| ☐ | Failed-payment recovery configured | You | Retry schedule and patient messaging set; refills hold until payment clears |
| ☐ | Refund and cancellation policy enforced in code | Both | What the policy says is what the storefront does |
| ☐ | Revenue and retention reporting visible | MyOrbitHealth | OrbitOS reporting shows orders, revenue and retention for your tenant |
| ☐ | Tax and receipts set | You | Receipts carry your brand and the right tax treatment for your states |
Phase 10: Ad accounts and pixels
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Google Ads account opened and linked to certification | You | LegitScript certification attached; Google approval requested |
| ☐ | Meta and Microsoft accounts opened | You | Healthcare authorization requested where required |
| ☐ | Pixel placement reviewed against PHI boundaries | Both | No ad pixels on intake, portal, results or any page that collects health information |
| ☐ | Conversion events defined on safe pages | You | Checkout-complete and landing-page events fire without health data |
| ☐ | Landing pages compliant | You | No prescription-drug promotion where policy prohibits it; required disclosures present |
| ☐ | Organic and partner channels prepared | You | Content, email list, creator or affiliate program ready to start before ads are approved |
The pixel rule is not optional. The FTC's Health Breach Notification Rule reaches health sites outside HIPAA, and both FTC and HHS have pursued tracking-technology cases. HIPAA for founders covers the boundary.
Phase 11: Support playbooks
Support splits into non-clinical (orders, shipping, billing, account) and clinical (symptoms, side effects, dosing). Your team runs the first; licensed providers answer the second through the portal.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Support tiers defined | You | Non-clinical questions answered by your team; clinical questions routed to providers |
| ☐ | Escalation path for clinical and adverse-event messages | MyOrbitHealth | Red-flag messages reach a provider under a documented path |
| ☐ | Shipping-issue playbook | Both | Lost, delayed or damaged shipment steps, including cold-chain failures |
| ☐ | Refund and cancellation playbook | You | Scripts and approval thresholds written |
| ☐ | Response-time targets set | You | Internal targets for first reply and resolution |
| ☐ | Help center and macros written | You | Top twenty questions answered in your voice |
Phase 12: Soft launch
Run a small, controlled cohort (email list, founders' network, a single geography) before paid traffic. Watch a short list of signals qualitatively; the goal is to find breaks, not to prove unit economics.
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | Internal dry run | Both | A test patient completes intake, provider review, prescription, payment and shipment |
| ☐ | Cohort invited | You | First real patients from an owned channel |
| ☐ | Intake completion watched | You | Where patients abandon intake is known and fixed |
| ☐ | Time to provider decision watched | MyOrbitHealth | Queue health and response times visible in OrbitOS; average under six minutes during business hours network-wide |
| ☐ | Approval, decline and escalation mix reviewed | Both | Mix matches what the protocol expects; surprises investigated |
| ☐ | Ship times and tracking reviewed | Both | Orders reach patients with working tracking; cold-chain intact |
| ☐ | Support tickets per order reviewed | You | Top ticket reasons identified and fixed in copy, flow or playbooks |
| ☐ | Failed payments reviewed | You | Retry and messaging working; no refills shipped unpaid |
Phase 13: Go-live
| Item | Owner | Done when | |
|---|---|---|---|
| ☐ | All phase 1 to 11 items closed | Both | Every box above checked with a named owner |
| ☐ | LegitScript approved and ad accounts approved | Both | Paid channels open |
| ☐ | Monitoring on | MyOrbitHealth | Uptime, latency and queue health visible in real time in OrbitOS |
| ☐ | Launch-day staffing | You | Support and marketing on shift; clinical coverage 24 hours through the network |
| ☐ | First paid campaign live | You | Budget capped; creatives approved |
| ☐ | First-week review scheduled | Both | Metrics from phase 12 reviewed with real traffic |
Each step, who does it
| Step | MyOrbitHealth runs | You run |
|---|---|---|
| Offer and states | Scope confirmation at onboarding | Vertical, states, price, plan design |
| Entity and banking | Merchant-of-record confirmation | Company, EIN, bank, merchant account, trademark |
| Agreements | BAA, MSO / friendly-PC clinical structure, platform agreement | Counsel review, policies, consents |
| Platform onboarding | OrbitOS tenant, provider routing, sandbox keys | Team roles, webhook endpoints if integrating |
| Brand and offer | Claims review support | Brand assets, copy, pricing, templates |
| Storefront and app | Storefront, patient portal, native iOS/Android app | Domain, subscription products, legal pages |
| Intake | Orbit Intake engine, clinical review, identity verification, red-flag escalation | Tone, decline messaging, consent wording with counsel |
| Pharmacy and labs | OrbitRx via Surescripts, LegitScript-certified pharmacies, cold chain, 0% markup, Orbit Labs | Formulary choices, catalog decisions |
| LegitScript | Prepares, files and manages to approval | Documents, site accuracy, fees |
| Payments | Subscriptions, reporting | Processor, dunning, refunds, tax |
| Ads and pixels | PHI-boundary guidance | Accounts, creatives, landing pages, conversion events |
| Support | Clinical escalation through providers | Non-clinical support, playbooks, help center |
| Soft launch and go-live | Queue health, uptime, routing fixes | Cohort, metrics review, campaigns |
What usually breaks in the first week?
Four things, in our experience across 50+ digital clinics on the platform. Intake drop-off at a question that feels intrusive or unnecessary; fix by cutting what the protocol does not need. A state that was in the ad targeting but not in the routing table; fix by reconciling the two lists before the campaign goes live. A shipping expectation gap, where patients expect next-day delivery of a cold-chain compounded product; fix in checkout copy and the first email. And support tickets that are really clinical questions landing on a non-clinical team; fix by making the portal's provider messaging obvious. None of these are platform failures. All of them are launch-list failures, which is why the list exists.
Frequently asked questions
What is the first thing to do when launching a telehealth business?
Pick one launch vertical and the states you will serve, then form the operating company and start merchant underwriting. The offer decision drives every downstream choice (modality, pharmacy, labs, consent), and the merchant account is a slow, external dependency that should start in week one.
What does a founder handle versus the platform?
On MyOrbitHealth the founder owns the company, brand, pricing, marketing, payment processor and non-clinical support. MyOrbitHealth runs the licensed provider network, Orbit Intake, OrbitOS, OrbitRx e-prescribing and pharmacy routing, Orbit Labs, the compliance infrastructure with a BAA in every contract, and the LegitScript filing through approval.
When should I file for LegitScript certification?
As soon as the entity exists, the privacy and prescribing policies are written, the pharmacy relationships are in place and the website reflects all of it. Certification gates paid advertising on Google, and Meta and Microsoft recognize it, so the filing date sets your paid-acquisition date. Approval timing is LegitScript's decision.
Can I run ads before LegitScript approval?
Not for telemedicine services that can result in a prescription on Google, which requires LegitScript certification plus Google approval. Use the waiting period for organic content, email, creator and partner channels, and for a soft launch to an owned audience.
Where can I put advertising pixels on a telehealth site?
Only on pages that do not collect or display health information, such as marketing landing pages and a checkout-complete confirmation that carries no clinical data. Keep pixels off intake, the patient portal and results pages, and document the decision; tracking-technology cases have been brought under both HIPAA and the FTC Health Breach Notification Rule.
What should a telehealth soft launch measure?
Intake completion and where patients abandon, time from intake to provider decision, the approval and decline mix against what the protocol predicts, ship times and tracking reliability, support tickets per order, and failed-payment recovery. Treat these as diagnostics for the launch, not as benchmarks; published industry rates vary too much by vertical to be useful.
How long does a telehealth launch take on white-label infrastructure?
MyOrbitHealth brands go live in days once onboarding starts, because the provider network, pharmacy routing, labs and compliance layer already exist. The founder's entity work, merchant underwriting and LegitScript filing set the calendar, and the week-by-week sequence is in the telehealth launch timeline post.
Sources
- 45 CFR 164.504(e), Business associate contracts
- HHS Office for Civil Rights, Business Associates guidance
- FTC Health Breach Notification Rule, 16 CFR Part 318
- Google Ads Healthcare and medicines policy
- LegitScript Healthcare Merchant Certification
- 21 CFR Part 1311, Electronic prescriptions for controlled substances
Work the list with a partner that has already done it 50+ times
Bring the company, the brand and the offer. MyOrbitHealth brings 2,400+ board-certified providers in all 50 states, Orbit Intake, OrbitOS, OrbitRx at 0% medication markup, Orbit Labs, a branded storefront, portal and native app, and managed LegitScript certification, with a BAA in every contract and no revenue share. Book a demo and we will walk this checklist against your vertical and states, or start with the DTC brands solution.
