What a GLP-1 Telehealth Subscription Must Tell You Before You Pay

Quick answer

Before you pay for any auto-renewing GLP-1 telehealth subscription in the United States, you are entitled to see the full price and renewal terms in plain sight before your card details are collected, to give clear consent to the recurring charge, and to have a simple way to stop it. Those three protections come from a federal law called ROSCA, and several states add their own rules on top. You are also entitled to know that a compounded medication is not FDA-approved as a final product, to confirm that the prescriber holds an active license in your state, and to confirm that the dispensing pharmacy is licensed by a state board of pharmacy. A prescription is never a given: medication is prescribed only if a licensed physician determines it is appropriate for you.

Why "negative option" is the phrase to know

Most telehealth weight-management plans are sold as subscriptions that keep billing until you cancel. In consumer law this is called a negative option: your silence is treated as agreement to the next charge. Congress explained the problem when it passed the Restore Online Shoppers' Confidence Act (ROSCA) in 2010. The findings section of the law describes sellers that "periodically charged consumers until consumers affirmatively canceled the memberships" and notes that this practice "took advantage of consumers' expectations that they would have an opportunity to accept or reject the membership club offer" (15 U.S.C. 8401).

A subscription model is not wrong in itself. The question is whether the company tells you the truth about it before you pay and lets you leave when you want to.

The federal baseline: three things ROSCA requires

ROSCA is short and specific. Under 15 U.S.C. 8403, a company selling online with a negative option feature may not charge you unless it does all three of the following.

1. Clear disclosure before billing. The statute requires that the seller "provides text that clearly and conspicuously discloses all material terms of the transaction before obtaining the consumer's billing information." The statute does not list the material terms. As a practical reading, the recurring price, how often it renews, whether the medication and the physician visit are one charge or two, and how to cancel are the terms a reader would expect to see before typing in a card number.

2. Express informed consent. It requires that the seller "obtains a consumer's express informed consent before charging the consumer's credit card, debit card, bank account, or other financial account." Ask yourself whether you actively agreed to the recurring charge, or whether agreement was assumed for you.

3. A simple way to stop. It requires that the seller "provides simple mechanisms for a consumer to stop recurring charges from being placed on the consumer's credit card, debit card, bank account, or other financial account." ROSCA does not define "simple." The stricter standard, that cancellation must be as easy as sign-up, appears in some state laws, such as New York's, described below. These requirements apply regardless of your state.

The FTC Act: deception is unlawful on its own

Even where ROSCA does not reach, section 5 of the Federal Trade Commission Act applies. It states that "unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful" (15 U.S.C. 45(a)(1)). A price shown as monthly when the plan actually requires a multi-month prepayment, a "no hidden fees" claim beside a separate membership fee, or a cancellation promise the company does not honor can all be examined under this standard.

Where the FTC "click to cancel" rule stands today

Here is the status of the FTC's "click to cancel" rule, checked against primary sources on the date this article was written.

On October 16, 2024, the FTC announced a final rule amending its Negative Option Rule. The announcement described prohibitions on "failing to clearly and conspicuously disclose material terms prior to obtaining a consumer's billing information," "failing to obtain a consumer's express informed consent to the negative option feature before charging the consumer," and "failing to provide a simple mechanism to cancel the negative option feature and immediately halt charges."

That 2024 rule was challenged in court. On July 8, 2025, the United States Court of Appeals for the Eighth Circuit, in Custom Communications, Inc. v. Federal Trade Commission (No. 24-3137, consolidated with No. 24-3388), wrote: "we grant the petitions for review and vacate the Rule." The court's stated reason was procedural: the Commission "failed to follow procedural requirements under § 22 of the Federal Trade Commission Act."

The FTC has since described the 2024 rule as "the vacated 2024 Rule" in a March 11, 2026 press release, and the Commission's Negative Option Rule page lists a February 12, 2026 Federal Register notice titled "Revision of the Negative Option Rule ... To Conform These Rules to Federal Court Decisions" and a March 13, 2026 Advance Notice of Proposed Rulemaking asking for public comment on new amendments. The FTC's March 11, 2026 notice describes the "Rule Concerning the Use of Prenotification Negative Option Plans, commonly known as the Negative Option Rule" as "the current Rule" and asks whether to address negative option practices by "retaining the current Rule, adopting provisions of the vacated 2024 Rule or some other provisions," or by other means.

What this means for you: the 2024 "click to cancel" rule is not in force. ROSCA and the FTC Act are. A company that says a federal one-click cancellation rule protects you is out of date; a company that says no federal law governs its cancellation practices is also wrong.

State automatic-renewal laws add specifics

Many states have their own automatic-renewal statutes, and some go further than ROSCA. Three examples, quoted from the official legislative sites:

California (Business and Professions Code 17600 et seq.). The Legislature's stated intent is "to end the practice of ongoing charging of consumer credit or debit cards or third party payment accounts without the consumers' explicit consent for ongoing shipments of a product or ongoing deliveries of service" (section 17600). Section 17602(a) makes it unlawful to charge a card "without first obtaining the consumer's affirmative consent to the agreement containing the automatic renewal offer terms," and requires "an acknowledgment that includes the automatic renewal offer terms or continuous service offer terms, cancellation policy, and information regarding how to cancel in a manner that is capable of being retained by the consumer." Under section 17602(d)(1), a business that lets you accept the offer online must let you "terminate the automatic renewal or continuous service exclusively online, at will, and without engaging any further steps that obstruct or delay the consumer's ability to terminate," through "a prominently located direct link or button" or "an immediately accessible termination email formatted and provided by the business that a consumer can send to the business without additional information."

New York (General Business Law 527-a). It is unlawful to "fail to present to the consumer, in a clear and conspicuous manner, the material terms of any automatic renewal offer or continuous service offer, including but not limited to a description of the product or service subject to renewal, the amount of the costs that will be charged, the frequency of charges, the deadline by date or frequency by which the consumer must act to prevent or stop further charges, and cancellation mechanisms" described in the statute. It also requires "a simple cancellation mechanism that is as easy to use as the mechanism that the consumer used to provide consent and that is through the same medium that the consumer used to provide consent."

Oregon (ORS 646A.292 to 646A.295). Oregon's required "offer terms" include "That the subscription or purchasing agreement will continue until the consumer cancels," the recurring charges "and, if the amount of the charge will change, the amount to which the charge will change, if known," and "The minimum purchase obligation, if any." Businesses must provide a "cost-effective, timely and easy-to-use mechanism for cancellation."

If you live in another state, your attorney general's website is the place to look for the equivalent law. The common thread: terms before consent, consent before charge, and a cancellation path no harder than the sign-up path.

What the FDA says about compounded medications

Many telehealth GLP-1 programs prescribe compounded medications. The FDA's compounding questions-and-answers page states it plainly: "Compounded drugs are not FDA-approved. This means that FDA does not verify the safety, effectiveness or quality of compounded drugs before they are marketed."

The FDA also explains who watches over compounders: "Generally, state boards of pharmacy have primary responsibility for the day-to-day oversight of state-licensed pharmacies that are not registered with FDA as outsourcing facilities."

On buying through telehealth specifically, the FDA writes: "With respect to any online pharmacy or telehealth service, including those that market compounded drugs, FDA encourages consumers to research the online pharmacy before using its services," and warns that consumers "may not know the identity of the compounder that produced the drug, including whether the drug was produced by a compounder whose drugs meet appropriate quality standards and that is appropriately licensed and regulated."

The practical consequence: a provider offering a compounded GLP-1 medication should tell you, before you pay, that the product is not FDA-approved as a final product, and should name the dispensing pharmacy so that you can check its license yourself.

How to verify the prescriber and the pharmacy

The prescriber. State medical boards license physicians and publish license lookups. The Medical Board of California, for example, publishes a physician profile that "provides information about the licensee," and its License Alert mobile app sends a "notification when a doctor is suspended, revoked, or placed on probation." Search your own state's board for the clinician's name and look for an active license in the state where you are located.

The pharmacy. The California State Board of Pharmacy, for example, lets you search both "Personal License" and "Facility License" types, including "Pharmacies" and "Non-Resident Sterile Compounding," notes that "information on the board's Web site can be accepted as verification of a license," and states that results "will indicate "Yes" under the Actions column if there is disciplinary information." Ask the provider for the pharmacy's legal name and state, then search that state's board.

A provider that will not name its pharmacy or its physicians has not given you what you need to run these checks. Knowing which state's license to ask about comes first, and our explainer on which state's license governs a telehealth visit covers that rule.

Eight questions to ask any provider before you pay

1. What is the total recurring charge, how often does it renew, and does it change after the first period?
2. Is the physician visit a separate fee from the medication, and is either charged before a physician decides whether to prescribe?
3. What happens to my money if the physician determines that medication is not appropriate for me?
4. How do I cancel, through which channel, and how quickly do charges stop after I cancel?
5. Is the medication compounded, and if so, does your written material state that it is not FDA-approved as a final product?
6. Which pharmacy dispenses the medication, in which state, and under which license number?
7. Which state-licensed physician will review my case, and in which state is that physician licensed?
8. Will I receive a written acknowledgment of the subscription terms and cancellation policy that I can keep?

If any answer is missing, vague, or only available after you enter payment details, the law described above is on your side, and so is the option to walk away.

This article is educational. It is not legal advice or medical advice, and it does not describe any specific company's practices. Laws change; every source below was read on the date shown. If you believe a company has violated a consumer protection law, contact your state attorney general or report it to the FTC. Medication is prescribed only if a licensed physician determines it is appropriate.