The Pulse
The FTC sued Hims over how it bills and how hard it is to cancel.
On July 29 the FTC, joined by Utah and Los Angeles County, filed a complaint against Hims & Hers in the Northern District of California.
The privacy claims got the headlines: sharing condition-level health events with Meta, Snap and other ad platforms while promising discretion.
The billing claims are the ones operators should read twice. The complaint alleges most patients were charged and enrolled in a recurring plan right after submitting an intake form, without the provider consultation they were promised, and that the cancel button sat behind an "add or remove items from order" menu.
None of that is a legal theory. It is a description of a lifecycle flow that somebody built on purpose.
Teladoc's cash-pay base keeps shrinking.
Teladoc reported Q2 the same day: revenue of $606.9M, down 4% year over year, and a net loss of $38.9M.
BetterHelp carried most of the damage. Revenue fell about 12% to $213M and average paying users dropped 11% to 346,000, with full-year guidance cut on the back of it.
Insurance-covered users grew while cash-pay users left.
The subscriber who re-authorizes a charge out of their own pocket every month is the hardest one in healthcare to keep, and for a DTC telehealth brand that subscriber is the entire business.
The subscription rulebook is being rewritten while this plays out.
The Eighth Circuit vacated the FTC's click-to-cancel rule in July 2025. The agency reopened the rulemaking with an advance notice in March 2026 and kept enforcing under ROSCA in the meantime.
Uber and LA Fitness are already in that enforcement queue. Hims is the first large telehealth name in it.
Assume the eventual standard looks like the vacated one: clear terms, express consent, and a cancel path as simple as the signup path. Building to that now is cheaper than retrofitting under a consent decree.
The Deep Dive
A lot of telehealth retention numbers are propped up by friction, and friction just became a line item in a federal complaint.
Read the FTC's allegations as a flow audit instead of a legal story.
Three design choices got named, and every one of them was made by somebody in a lifecycle tool, not by a lawyer.
1. The charge lands before the patient feels seen.
The complaint alleges most patients were billed and subscribed right after submitting intake, without the consultation the marketing promised.
Set the legal question aside for a second.
A patient charged before they believe a clinician looked at their case starts month 1 feeling processed rather than treated. That patient churns at the first side effect, and no day-14 email saves them.
2. The refill fires before the patient's cancel window closes.
The complaint alleges refills processed roughly 10 days earlier than patients expected, with cancellation required two days before that.
A billing cycle that beats the patient's mental calendar does not retain anyone.
It delays the exit by one charge, and it converts a quiet cancellation into a chargeback, a support ticket, and a one-star review.
Patients had to open "add or remove items from order" and clear their medications before the word cancel appeared.
That design does hold the churn number down for a quarter.
It also guarantees the patient leaves angry, and angry patients do not come back.
That last part is the expensive one, and it is the part most operators never price in.
Roughly 41.5% of patients who quit a GLP-1 restart treatment within a year. Winback is the cheapest revenue in the building, and it only works if the exit was clean.
Every patient you trap is a winback you have already written off. You booked one more charge and gave up the whole second lifecycle.
The version that survives both the regulator and the P&L is unglamorous:
Charge after the clinical review, and say so plainly in the confirmation.
Put the refill date in the patient's hands, with a reminder before it fires rather than a receipt after.
Make cancel one click from account settings, then put your best save inside the flow instead of in front of it.
That third one is where the money is. We run the save off the stated reason, and for price objections the offer is a switch to a multi-month plan at a lower effective monthly cost, not a flat discount.
It recovers roughly 8 to 12% of price-objection cancellations for our clients, and it raises commitment length instead of cutting margin.
The save works because the patient chose to stay, not because they could not find the button.
Takeaway: if your retention depends on a patient failing to find something, you do not have retention. You have a delay, and as of last week it is a legal exposure sitting on top of a revenue one.
Quick Takes
The audience you built to acquire is a liability you carry to retain.
The privacy half of the complaint is about condition-level events flowing to Meta and Snap.
A telehealth conversion event has a diagnosis inside it. That is exactly what makes those audiences perform and exactly what makes them dangerous.
Pull the list of events your pixel actually fires and read it as if a regulator were reading it, because that is now a real possibility.
Cash-pay is the hardest retention job in healthcare, and small brands have no hedge.
Teladoc's insurance users grew last quarter while cash-pay paying users fell 11%.
The large platforms can absorb that by leaning into covered channels. A DTC telehealth brand cannot.
When every patient re-decides every month, a month spent on lifecycle work beats a month spent on new ad creative almost every time.
One Thing to Try
Cancel your own subscription this week.
Have someone outside the growth team sign up as a patient and then try to leave, with a stopwatch running.
Count three things: clicks from account settings to the cancel button, days between the advertised billing date and the date the charge actually fires, and whether any save offer appears at all.
If cancel takes more than two clicks, or the charge lands more than three days early, fix those two before you touch anything else in the flow.
Then add one reason-based branch at the exit: for the price objection, a switch to a multi-month plan at a lower effective monthly rate. That single branch recovers 8 to 12% of price-objection cancellations and takes under an hour to build.
If retention is your biggest revenue leak, that’s what we fix. growthtrigger.xyz
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