Payments · Telehealth7 min readUpdated November 2, 2026

How to Handle Telehealth Subscription Cancellations Without Breaking State Rules

How telehealth brands handle plan cancellations under ROSCA, California law and Visa rules: pending prescriptions, shipped orders, retention offers.

Nick Bonnassies, CMO at Tagada · checked against 13 sources

Article summary

TL;DR

Let patients cancel the way they signed up, online, in a few clicks, and stop the next charge at once. ROSCA's "simple mechanisms", California's auto-renewal law and Visa's rules ask for that. A retention offer is allowed if a clear "cancel" option sits next to it. Decide ahead what happens to a prescription under review or a shipped order.

ROSCA requires "simple mechanisms for the consumer to stop recurring charges" for any online negative option sale.
The FTC's "click-to-cancel" rule was vacated on July 8, 2025; as of November 2, 2026, no replacement has been proposed.
California requires online cancellation for online sign-ups, with a visible "click to cancel" option if you show a save offer (contracts from July 1, 2025).
Visa requires online cancellation when the order was taken online (rules of April 18, 2026).
On July 29, 2026, the FTC and two states sued a telehealth company, alleging it made cancellation hard "by hiding the cancellation button from consumers".

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On this page

This guide is part of our hub on telehealth payment processing. The general guide, for any business: subscription payment rules.

Here we cover the exit: cancellation, pauses and refunds. Sign-up terms and consent are in how to sell telehealth on subscription.

The rules that apply when a patient cancels

No rule is specific to telehealth. Your treatment plan is a recurring charge, so federal law, state auto-renewal laws and card network rules all apply.

Rule	What it says about cancelling	Status
ROSCA (federal)	"Simple mechanisms for the consumer to stop recurring charges"1	In force
FTC "click-to-cancel" rule	Would have required cancelling as easy as signing up	Vacated July 8, 2025; 1973 text restored February 12, 2026; comment period opened March 13, 2026; no proposed rule as of November 2, 20262 3
California, Bus. & Prof. Code § 17602	Online cancellation for online sign-ups; "click to cancel" option if you present a retention offer; yearly reminder of how to cancel4	Contracts from July 1, 2025
Other states	The FTC cites California, Colorado, Vermont and Virginia as examples of state auto-renewal laws2	Varies by state
Visa	Online cancellation when the sale was online; a cancel link in trial-ending notices5	Rules of April 18, 2026
Mastercard	An online cancellation method; confirmation after sign-up with cancellation instructions6	Since 2022

Fig. 1The FTC click-to-cancel rule, and what still applies

July 8, 2025Click-to-cancel rule vacated
February 12, 20261973 text restored
March 13, 2026Comment period opened
November 2, 2026No proposed rule; ROSCA, California and Visa still apply

The federal rule is gone for now; ROSCA, state laws and the networks aren't.

FTC, Federal Register notices of February 12 and March 13, 2026; Cal. Bus. & Prof. Code § 17602; Visa Core Rules, April 18, 2026.

If you sell nationwide, a common approach is to build one flow to California's standard, the most detailed of the state laws, then check the other states where your patients live with your counsel.

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

What the FTC has alleged in telehealth

Two telehealth cases show where enforcement looks. Both are about subscriptions and cancellation, along with health data.

Hims & Hers (filed July 29, 2026, ongoing)
The FTC alleges consumers were enrolled in recurring plans "shortly after receiving consumers' intake forms", charged for a prescription "without having a chance to review or approve it", and kept from cancelling "by hiding the cancellation button from consumers"7. These are allegations, not findings.
Cerebral (proposed order, April 15, 2024)
Despite a "cancel anytime" promise, a cancellation process that was "complex, multi-step, and often multi-day"; more than $7 million in total under the order8.

Outside health, Loeb & Loeb lists ROSCA cases against Chegg ($7.5 million settlement) and LA Fitness over hard-to-find or in-person cancellation9.

Watch out

A cancellation that sends patients to chat, a phone line or an email form when they signed up online is exactly what these cases describe. Each blocked cancellation is also a likely chargeback: see telehealth chargebacks.

Telehealth cases: pending prescriptions, shipped orders, pauses

Treatment plans have moments a normal subscription doesn't. Write your answer to each into your terms, and show it in the cancellation flow.

Situation	What to do	Why
Patient cancels while the clinician is still reviewing	Release the card hold, confirm cancellation	Nothing was prescribed; charging would be hard to defend
Clinician declines the prescription	Release the hold; never start the plan	"Declined, cancelled, and errored cases never rebill" is the standard to aim for11
Patient cancels after the pharmacy shipped	Cancel future charges; state your refund policy for the shipped order before checkout	Terms disclosed up front decide the dispute
Patient cancels mid-cycle	Stop the next charge; access until the end of the paid period, if your terms say so	Matches what the patient already paid for
Patient wants a break	Offer pause or skip, next to cancel, never instead of it	Retention without blocking the exit4
Price of the plan changes	Notify before it applies, with how to cancel	California: 7 to 30 days before4

For billing cycles tied to shipping, see prescription-gated checkout.

Retention offers that don't block the exit

You can try to keep a patient. You just can't make the offer a wall.

Show the offer and the cancel button on the same screen. California requires a "click to cancel" option when you present a save offer4.
Offer real alternatives: pause, skip a refill, change frequency, a lower-cost plan.
One offer, once. A chain of screens is what the FTC cases describe7 8.
No reason required to cancel. Ask for feedback, optionally.
Confirm by email with the cancellation date and the last charge.

Fig. 2A save offer, or a wall

Offer as a wall

CancelFrom the account page
leads toOffer after offerA chain of screensDeclined
thenChat or phoneTo finish cancellingDeclined

Exit blocked: the pattern the FTC cases describe

Offer next to cancel

CancelFrom the account page
leads toOne retention screenCancel my plan as visible as the offerApproved

Cancelled, confirmed by email

Same offer; only one of these lets the patient leave.

Illustrative example.

The retention side, with flows and offers: subscriptions and churn for telehealth companies.

A compliant cancellation flow, step by step

Link "Cancel" from the account page and from every renewal and trial-ending email5.
Authenticate simply: a login or an email code, not a call.
Show one retention screen, with "Cancel my plan" as visible as the offer4.
Cancel immediately and stop the next charge, whatever the outcome of a pending review.
Send a confirmation that the patient can keep, with the date and what happens to any pending order.
Log the request with a timestamp: it's your evidence if the patient disputes a later charge.
Review monthly: cancellations, refund requests and disputes for cancelled plans, side by side.

Keep the timestamped log: it's your evidence if the patient disputes a later charge.

How Tagada helps

Pause, skip and cancel in a customer portal

TagadaPay keeps "Your PCI-tokenized cards, your customer profiles, your subscription data, all portable"13, and the Tagada subscription engine handles the cancellation side.

Customer portal: patients can "skip, pause, change frequency, swap product, cancel with your retention offers"; pauses are capped by you, "90 days by default"10
Cancellation at the end of the paid period by default10
Subscription engine with trials, billing cycles, retries and automatic recovery
Routing across TagadaPay and processors such as Stripe, NMI and Airwallex, with a cascade to another processor when one is down or times out

Setup details: subscriptions for telehealth companies.

Building a telehealth brand from scratch? Tagada Rx runs storefront, doctors, pharmacy and payments in one stack12, refills rebill on ship day, and "Declined, cancelled, and errored cases never rebill"11. US patients only, by selection.

Apply for processing

Pause, skip and cancel in a customer portal

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

Is the FTC's click-to-cancel rule in effect in 2026?

No. The Eighth Circuit vacated it on July 8, 2025, and the FTC restored the 1973 text on February 12, 2026. It opened a new comment period on March 13, 2026, with no proposed rule as of November 2, 2026. ROSCA and state laws still require simple cancellation.

Do I have to let patients cancel online?

If they signed up online, effectively yes. California requires online cancellation for online sign-ups, and Visa requires it when the order was taken online. ROSCA requires "simple mechanisms" to stop recurring charges.

Can I show a retention offer before cancelling?

Yes, if the patient can still cancel right away. California requires a "click to cancel" option when you present a save offer. Keep it to one screen, with cancel as visible as the offer.

What if a patient cancels after the medication shipped?

Cancel all future charges at once. Whether you refund the shipped order depends on the policy you disclosed before checkout, so write it down and show it. A charge after a cancellation request invites a dispute.

Can a telehealth plan require a minimum number of months?

Commitments are a legal question for your counsel: they must be disclosed clearly before payment under ROSCA, and state auto-renewal laws add their own requirements. Many brands prefer month-to-month plans with pause options, which are easier to defend.