Payments · Telehealth6 min readUpdated November 3, 2026

How to Sell Telehealth Services on Subscription

How to sell a telehealth care plan or membership on subscription: when to charge, ROSCA, Visa and Mastercard rules, renewals and checkout wording.

Nick Bonnassies, CMO at Tagada · checked against 13 sources

Article summary

TL;DR

Processors accept telehealth care plans and memberships billed on a cycle, if terms are clear and disputes stay low. Show the price, frequency and how to cancel before the card field, get express consent, confirm right after sign-up, remind before trials end, and allow online cancellation. The telehealth-specific risk: charging for a plan before a clinician reviews the case.

ROSCA requires material terms before billing details, express informed consent and "simple mechanisms" to stop charges.
Visa requires a reminder at least 7 days before a trial or introductory price ends, and online cancellation for online sign-ups.
Mastercard requires a confirmation with cancellation instructions and, for cycles of 6 months or less, a notice before billing.
On July 29, 2026, the FTC alleged a telehealth company enrolled consumers in recurring plans "shortly after receiving consumers' intake forms".
The FTC's click-to-cancel rule was vacated on July 8, 2025; the FTC restored the earlier rule text in February 2026 and only opened new rulemaking with an advance notice in March 2026.

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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 processing, from first charge to every renewal. Setting up the billing tool: subscription billing for telehealth companies.

Will processors accept a telehealth subscription?

Yes for most offers, if the patient sees and accepts the terms. Telehealth is already restricted at Stripe8, so the offer design is read closely at underwriting.

Offer	How processors see it	Why
One-time visit fee, no renewal	Simplest	NoRecurring charge to dispute
Monthly care plan, terms shown at checkout, billed after clinician review	Usually fine	Patient chose, saw the terms, got the service
Membership with unlimited messaging or visits	Usually fine with clear terms	Value delivered every cycle
Plan billed at intake, before any clinician review	High risk	The pattern alleged by the FTC in July 20266
Discounted first month rolling into full price, terms in small print	High risk; often refused	ROSCA disclosure and consent1; Visa trial rules2
Renewal added by a pre-checked box	Refused	NoExpress consent1

When to charge: before or after the clinician decides

Charge for treatment only once it's approved. The safe pattern is to authorize the card at checkout and capture after the clinician's decision. If the clinician declines, you void the authorization and the patient pays nothing.

Moment	What you can charge	Risk if you don't
Intake and checkout	Visit fee if it's sold as such; an authorization for the plan	Disputes for a service never delivered
Clinician approves	Capture the first plan payment	None: this is the normal path
Clinician declines	Void the authorization; refund any captured plan fee	"Not as described" disputes, FTC exposure6
Each renewal	The next cycle, after shipment or service	Renewals billed for paused or declined cases

Watch out

The FTC alleges that consumers were "charged for and subscribed to a prescription […] without having a chance to review or approve it", and that the company "does not give most consumers a consultation with a provider"6. These are allegations in a pending case, not a ruling. They show what regulators look at.

How to build the hold and capture: requiring a prescription before checkout.

The billing rules, step by step

Moment	What you must do
Checkout	Show price, frequency, trial length and how to cancel before billing details (ROSCA, Visa)1 2
Consent	Express consent; trial terms separate from general terms (ROSCA, Visa)1 2
Right after sign-up	Confirmation with the terms and how to cancel (Mastercard, California)3 4
Before a trial or intro price ends	Reminder at least 7 days before (Visa)2
Before each charge	Notice for cycles of 6 months or less (Mastercard)3
Every year	Annual reminder for California customers (California)4
Any time	Online cancellation for online sign-ups (Visa, Mastercard, California)2 3 4

Fig. 1A patient's path, and the rule at each step

CheckoutTerms before billing details; card authorized
Clinician decidesApprove or decline
CaptureFirst plan payment, on approval
ConfirmationTerms and how to cancel
ReminderAt least 7 days before a trial or intro price ends
Before each chargeNotice for cycles of 6 months or less
Any timeOnline cancellation

Charge for treatment only after the clinician approves.

ROSCA, 15 U.S.C. § 8403; Visa Core Rules; Mastercard subscription FAQs; California B&P Code § 17602.

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

Cancellation was the core of the FTC's 2024 order against Cerebral, over a "cancel anytime" promise it didn't honor7. State-by-state cancellation rules: handling cancellations without breaking state rules.

Renewals and refills

Bill the renewal when the patient gets something. For treatment shipped on a cycle, many brands rebill when the pharmacy ships rather than on a fixed calendar date, so a paused or declined case is never charged.

Retry limits
Visa allows up to 20 attempts in 30 days on a declined recurring payment, and none on category 1 codes such as closed accounts2.
Fees
Fees apply to each excess attempt: $0.10 domestic plus $0.05 cross-border10.
Paused or cancelled cases
Paused or cancelled cases stop billing immediately, including scheduled retries.

Refill and membership design: subscription billing and memberships for telehealth companies. Recovering failed renewals: failed payment recovery.

Checkout wording

Example

"Care plan: $79 a month, billed only if your clinician approves your treatment. Your card is authorized today and charged after approval. Next charges: every 30 days from shipment. We'll email you before each charge. Pause or cancel anytime online in your account."

Fig. 2What the patient reads above the pay button

Checkout · care planAuthorization today, charge on approval

Price: $79 a month, billed only if your clinician approves
Today: Card authorized, charged after approval
Next charges: Every 30 days from shipment
Before each charge: Email reminder
Cancel: Pause or cancel anytime online

Illustrative record.

Illustrative example.

Next to the pay button, not only in the terms page.
A separate, unticked checkbox for the recurring plan.
No diagnosis or treatment in the descriptor, product names or payment metadata: Stripe's agreement forbids sending it Protected Health Information9.
The same wording in the confirmation email, with the cancellation link.

Trial offers have their own rules: trial offers for telehealth companies.

How Tagada helps

Subscriptions, checkout and routing for telehealth billing

TagadaPay brings "Native 3DS2, device intelligence, and rules engine: approve real customers, block the rest"13, and keeps "Your PCI-tokenized cards, your customer profiles, your subscription data, all portable."

Customer portal: patients can skip, pause, change frequency or cancel online
Subscriptions with 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

Building a telehealth brand from scratch? With Tagada Rx, "Approve captures the hold. Decline voids it", "Recurring treatments rebill the day the pharmacy ships", and "Declined, cancelled, and errored cases never rebill"11. US patients only, by selection.

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Subscriptions, checkout and routing for telehealth billing

Updated on November 3, 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 a monthly subscription?

Yes, with clear terms and express consent under ROSCA, plus Visa and Mastercard subscription rules. Processors look at whether the patient sees the price, frequency and cancellation method before paying, and whether you charge for treatment before a clinician reviews the case.

Should I charge before or after the doctor approves?

After, for treatment. Authorize the card at checkout, then capture once the clinician approves, and void the authorization if they decline. A separately sold visit fee can be charged up front if the patient knows it's for the visit.

Do I need to send a reminder before each renewal?

Mastercard requires a notice before billing for cycles of 6 months or less. Visa requires a reminder at least 7 days before a trial or introductory price ends. California adds an annual reminder.

Do patients have to be able to cancel online?

Yes, if they signed up online: Visa, Mastercard and California all require it. The FTC's 2024 order against Cerebral and its 2026 complaint against Hims & Hers both centered partly on cancellation.

What should my billing descriptor say?

Your brand name and a support contact, nothing about the condition or treatment. Patients recognize the charge, and you keep health information out of your processor's data.

Sources

Checked November 3, 2026

TagadaPay

Telehealth renewals that stay inside the card rules

Tell us what you sell and how you sell it. Each application is underwritten, and approval is not guaranteed.

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01Tell us what you sell and how
02Underwriting reviews your business
03Process through TagadaPay alongside your other processors