Payments · Telehealth7 min readUpdated November 2, 2026

Consultation and Medication: Should Your Telehealth Brand Charge Them Separately?

Should a telehealth brand charge the consultation and the medication on one account or two? MCCs, Visa and Mastercard rules, Stripe and HSA/FSA.

Nick Bonnassies, CMO at Tagada · checked against 13 sources

Article summary

TL;DR

Usually, yes. The consultation is a medical service (Visa MCC 8011 or 8099); the medication is a pharmacy sale (MCC 5912), and only the pharmacy sale falls under Visa's and Mastercard's high-risk registration rules. Most telehealth brands charge the visit or membership themselves and let a licensed pharmacy, or a platform acting as merchant of record, charge for the medication.

Visa lists pharmacies (MCC 5122 and 5912) in Tier 1 of its Integrity Risk Program; telemedicine is in no tier.
Mastercard requires registration of "Non–face-to-face pharmaceutical Merchants", not of telemedicine providers (August 4, 2026 edition).
Stripe's main FAQ answers "Maybe" on selling medication; its Express FAQ says "In general, no" (both read November 2, 2026).
Since September 1, 2026, SIGIS says direct-to-consumer brands with their own pharmacy must keep "the medical consultation" separate "from prescription fees" for HSA/FSA cards.

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On this page

This guide is part of our hub on telehealth payment processing. The general guide, for any business: running more than one merchant account.

This page is about the telehealth brand: the visit, the prescription and the treatment plan. If you are the pharmacy, see online pharmacy payment processing.

Four ways to bill a telehealth visit and the medication

There are four common setups. What changes between them is who sells the medication, and therefore who carries the pharmacy rules.

Model	Who is the merchant for the medication	Likely MCC for the brand	What it means for you
1. Consult only, patient pays the pharmacy	The pharmacy the patient picks	8011 or 80991	Simplest account. Push Health, for example, says its fee "does not cover the cost of the medication"9
2. Brand charges both on one account	The brand	Can move toward 59121	Pharmacy rules apply to your whole account2 3
3. Two merchants: brand charges the visit or membership, a partner pharmacy charges the medication	The pharmacy	8011 or 8099	Two charges, two descriptors to explain at checkout
4. Platform as merchant of record for the regulated sale	The platform	Set by the platform	You run the brand; the platform carries the regulated relationship

Fig. 1Four ways the patient's money can flow

The patient paysFor the visit and the medication

1. Consult onlyBrand on 8011 or 8099; the patient pays the pharmacy
2. Brand charges bothOne account that can move toward 5912
3. Two merchantsBrand charges the visit, a partner pharmacy the medication
4. Platform as merchant of recordMCC set by the platform

What changes is who sells the medication.

Visa Merchant Data Standards Manual, October 2026; Push Health Support.

The merchant code isn't your choice. As SIGIS puts it, the acquirer assigns the MCC "according to card network rules"8. If your main business becomes selling medication, expect the pharmacy code.

Why the medication changes your card rules

The card networks have no telemedicine category. Their high-risk rules start when the merchant sells prescription drugs at a distance.

	Consultation, membership	Medication sold card-not-present
Visa MCC	8011 "Doctors and Physicians", 8099 "Medical Services and Health Practitioners"1	5912 "Drug Stores and Pharmacies"1
Visa Integrity Risk Program	Not listed2	Tier 1: registration with Visa before processing2
Visa exemption	Not needed	NoRegistration if accredited by NABP or LegitScript's Healthcare Merchant Certification2
Mastercard	NoCategory	Registration as a "Non–face-to-face pharmaceutical Merchant"; acquirer must verify legality, at least every 12 months3

Mastercard defines the sale as a purchase of "prescription medicines from a Merchant whose primary business is non-face-to-face selling of prescription drugs"3. A brand that only charges for the visit doesn't fit that definition.

Fig. 2One account or two merchants

Brand charges both

CheckoutVisit and medication
charged onBrand accountCan move toward 5912Declined

Pharmacy rules apply to your whole account

Two merchants

CheckoutTwo lines, two descriptors
visit toBrandVisit or membership, 8011 or 8099Approved
medication toPartner pharmacyMedication, pharmacy rulesApproved

The brand stays on a medical code

Selling the drug is what brings in the pharmacy rules.

Visa Integrity Risk Program guide, April 6, 2023; Mastercard Security Rules and Procedures, August 4, 2026.

Tagada follows Visa and Mastercard rules and the laws that apply to payments.

What processors say about selling the medication

Mainstream processors accept telemedicine with review. Selling the drug is where they hesitate.

Processor	Telemedicine	Selling the medication
Stripe	Restricted"Telemedicine and telehealth services"4	Main FAQ: "Maybe, this is a highly regulated industry"; pharmacies approved only in the US, Canada, the EU, Australia, the UK and Japan. Express FAQ: "In general, no. Payments for prescription medicines will need to occur outside Stripe."5
Square (US)	Not supported where medication follows a remote consult	Excludes pharmacies "where fulfillment of medication is performed with an internet or telephone consultation, absent a physical visit"6
Shopify Payments	Not named	"prescription drugs" listed among products that "require regulatory approval or compliance"7

Watch out

The two Stripe answers differ. Plan for the stricter one: if you sell medication, expect it to need a pharmacy-ready processor or a separate partner.

Processor by processor: does Stripe allow telehealth? and PayPal and Square for telehealth.

HSA and FSA cards: another reason to split

Health savings and flexible spending cards add their own logic. SIGIS, which runs the IIAS standard behind those cards, opened its certification to telehealth merchants on September 1, 20268.

Brands with their own pharmacy
"The medical consultation must be separate from prescription fees"8.
Medical MCC
"If a telehealth merchant is operating under a medical MCC they are not required to implement IIAS capability"8.
Pharmacy MCC
IIAS capability is required, and only prescription and eligible over-the-counter costs can run through it8.

Pharmacy Times reports that some operators use separate merchant accounts for "professional medical services" and "product fulfillment" for the same reason10.

How to set up a split checkout

If you charge the visit and a partner charges the medication, the patient sees two charges. Make both obvious before the card field.

Show two lines: the visit or membership price, and the medication price with who charges it.
Name both merchants and the descriptor each charge will carry.
Charge the medication only after a prescription. Authorize, then capture on approval: see prescription-gated checkout.
Release the hold if the clinician declines, and say so in your terms.
Keep medical details off the payment data: no treatment in descriptors or product names. See HIPAA and your payment processor.
Bill recurring plans by the rules: telehealth subscriptions.

The patient sees two charges: make both obvious before the card field.

How Tagada helps

One payment layer for consult and medication charges

TagadaPay runs "enhanced review for regulated verticals"13: each file is still underwritten. On the payment side:

Fraud and security: "Native 3DS2, device intelligence, and rules engine: approve real customers, block the rest"
Routing across TagadaPay and processors such as Stripe, NMI and Airwallex, with a cascade to another processor when one is down or times out
Your vault, portable: "Switch processors without re-onboarding customers"

The operations side: subscriptions for telehealth companies. Building the whole brand? In the "Merchant of Record" mode of Tagada Rx, "Tagada carries the regulated relationship"11, and "the card is only captured once a doctor approves"12. US patients only, by selection.

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One payment layer for consult and medication charges

Updated on November 2, 2026

Nick Bonnassies

CMO at Tagada

CMO at Tagada. Before Tagada, Nick built direct-to-consumer brands that generated over $115M in sales, raised over $25M in crowdfunding and sold two of them. He also works as a fractional CMO on marketing operations and AI systems.

Frequently asked questions

Can a telehealth company charge for both the visit and the medication?

It can, but selling the medication makes you a pharmacy merchant for the card networks: Visa Tier 1 registration and Mastercard registration apply to MCC 5912 sales. Many brands charge the visit or membership and leave the medication sale to a licensed pharmacy or a merchant-of-record platform.

What MCC does a telehealth company use?

Visa has no telehealth code. A physician consult fits 8011, other practitioners 8099, and dispensed medication 5912. Your acquirer assigns the code according to network rules, based on what you mainly sell.

Does Stripe let a telehealth brand sell prescription medication?

Stripe's main FAQ says "Maybe" and limits pharmacies to six regions; its Express FAQ says "In general, no". Telemedicine itself is restricted, not prohibited, and needs approval. Read does Stripe allow telehealth? before you plan around it.

Can patients pay with HSA or FSA cards?

It depends on your MCC and setup. SIGIS says a telehealth merchant under a medical MCC doesn't need IIAS, while a pharmacy MCC requires it, and brands with their own pharmacy must keep the consultation separate from prescription fees.

Do two charges hurt conversion?

It adds friction if it's a surprise. Show both prices and both merchant names before payment, charge the medication only after the prescription, and send a receipt for each. Surprise charges are what customers dispute: see telehealth chargebacks.