It really depends on shipping methods, packaging, and how low the temps are.

I once got a shipment of pumilios (around 16 years ago) in the middle of January in Colorado, during very frigid weather. Big mistake, as the frogs arrived practically frozen. I was able to bring them around, but it was not a pleasant experience.

I've been looking at some sites recently, and many of them don't have a live arrival guarantee if you ship below 40 degrees.