Telehealth Growth Desk: Q3 2026 Brief

$753.2 million. That is what Hims & Hers booked in revenue in the second quarter of 2026, up 38% on the year, and it landed less than two weeks after the FTC sued the same company.

Those two facts belong in the same briefing. Growth and scrutiny are now arriving together in telehealth, and an independent clinic running paid ads sits right between them. This desk note sorts the summer's news into what changes your Q4 plan and what you can safely file under "interesting."

Educational content only. It is not legal advice. Run your marketing, tracking and prescribing claims past a healthcare attorney.

What did the FTC actually allege against Hims & Hers?

Three families of claims: health data shared with ad platforms, charging before a provider consultation, and hard-to-cancel subscriptions.

The privacy allegations

The FTC alleges Hims gave Meta and Snap lists identifying certain customers, which disclosed health information, and used third-party tracking technologies that automatically sent visitor actions on its website to those companies. It also alleges the company shared sensitive information about medical conditions despite promising to protect patient privacy.¹

The billing and cancellation allegations

I broke this side down in FTC v. Hims & Hers. The FTC alleges Hims charged consumers almost immediately after they submitted an intake form, without a provider consultation, and enrolled them in recurring subscriptions. It also alleges refill timing was not clearly disclosed and that the cancel button sat behind several steps.¹

What it is not (yet)

The plaintiffs are the FTC, Utah and California, and the case was filed in federal court in the Northern District of California. The FTC's own page states the case will be decided by the court.¹ Do not repeat an allegation as a finding, in your content or in a sales call.

What do Hims & Hers' Q2 numbers tell an independent clinic?

That demand is real, and that scale costs money.

The headline

Revenue was $753.2 million against $544.8 million a year earlier. Subscribers ended the period at 2,891 thousand, up 19%, and monthly revenue per average subscriber rose 21% to $92.² Part of the jump came from the Eucalyptus acquisition, which closed in June and lifted Rest of World revenue to $131.4 million from $7.5 million.² US revenue grew 16%.

The fine print

Gross margin dropped to 64% from 76%. The company reported a net loss of $86.3 million, versus net income of $42.5 million a year earlier, and a quarter that included $47.5 million in legal contingencies.² Management guided Q3 revenue to $880 million to $900 million.²

My read, after 12 years of running Meta ads: the lesson is not "copy the giant." It is that growth and margin pull in opposite directions when a category gets crowded and regulated. A clinic with a few hundred patients and clean unit economics is in a different game than a public company buying scale.

What did the FDA say about compounded GLP-1 marketing?

It said it twice in 2026, and the second time got specific.

March: 30 warning letters

On March 3, 2026 the FDA announced warning letters to 30 telehealth companies over false or misleading claims about compounded GLP-1 products on their websites. It cited claims that implied sameness with FDA-approved products and branding that obscured who the compounder was.³ The agency repeated that compounded drugs are unapproved, which means it never evaluates them for safety, effectiveness or quality before marketing.³

June: a checklist for telehealth marketers

By mid-June the FDA had published a page for telehealth companies on promoting compounded drugs. It lists five claim types it treats as false or misleading:⁴

If your site, ads or intake copy uses any of those phrases, fix them first. Website copy is where enforcement starts. This is the cheapest risk reduction in the whole brief.

How did the branded pill change the picture?

It gave patients a branded option and gave marketers one more thing to describe accurately.

The FDA approved the Wegovy pill on December 22, 2025. Novo Nordisk said the starting dose would be $149 per month with savings offers and would reach pharmacies and select telehealth providers in early January 2026.⁵ For a clinic, the practical point is wording. A branded product and a compounded product are different things, and your copy must never blur them.

What should an independent clinic do before Q4?

Run an audit, in this order. None of it needs a bigger budget.

Copy

Read every ad, landing page and intake screen against the FDA's five claim types. Remove anything that implies sameness, approval or sourcing you cannot back up.

Tracking and audiences

Check what your pixel and any server events send (new pixels may start with Automatic Events switched on). Event names should describe business actions like Lead or Purchase, not conditions or drugs. Keep patient lists out of ad platforms. On audiences, the short version is that a list's meaning travels with it, so patient files stay out of ad platforms (details in Customer List Audiences Without Leaking Sensitive Data).

Billing and cancellation

Look at your checkout the way the FTC's allegations frame it: when does the card get charged, is a provider consult clearly part of the flow, is refill timing stated and can a patient cancel in one obvious step?

Growth

Only then decide spend. For a full review of funnel, tracking and compliance guardrails, that is what the telehealth program is for.

What I would ignore

Headlines about a competitor's stock price, a rival's valuation or who is up this week. None of it changes whether your page can make a claim, whether your pixel sends a condition or whether your cancel button is findable. Spend the attention on the three things you control: what you say, what you send and how you bill.

The summer's news will keep moving. The clinics that look calm in Q4 will be the ones that cleaned up in September.

Keep building.Ekai