Telehealth Growth Desk: Q4 2025 Brief

Three things moved this quarter. Only one of them lands directly on the revenue of a cash-pay telehealth clinic. This desk exists to tell you which, so you spend October on the right work.

This is an operator's briefing, not legal advice. Bring anything that matters to counsel who knows your state and your products.

What is the signal this quarter?

Start with a simple filter, the change test. For each headline, ask whether it changes what you can say, what you can charge, or what you can legally do. If it changes none of the three, it is noise for your month.

Here is the quarter through that filter.

Does the FDA's September crackdown reach a cash-pay clinic?

Yes, and this is the one to read twice. (I broke down the letters in The FDA's Drug Ad Crackdown Reaches Telehealth.)

On September 9, 2025, the FDA and HHS announced a push against misleading drug advertising. The agency said it was sending thousands of letters warning companies to remove misleading ads, plus about 100 cease-and-desist letters to companies with deceptive ads, and that it would begin rulemaking on a long-standing "adequate provision" loophole.¹ The press release itself talks about direct-to-consumer drug advertising and paid influencer promotion.

The telehealth angle came out in the commentary. Holland & Knight reports that, unlike earlier actions, the FDA sent warning letters to telehealth providers and companies, including several GLP-1 providers, and said the products were misbranded because of misleading ads.² Examples of flagged language included "Semaglutide (the same ingredient in Wegovy & Ozempic)" and "TIRZEPATIDE (GENERIC MOUNJARO)."²

If your site, your ads or your emails use anything like that line, you are the audience for this story. Sameness language is the new red flag.

What to check this week

• Any headline or ad that compares your product to a brand name.
• Any phrase like "generic," "same as," "equivalent to" or "the active ingredient in."
• Influencer or affiliate posts that do not clearly disclose payment. The FDA release specifically calls out undisclosed paid influencer promotion.¹
• Before and after claims with no support behind them.

Do the Medicare telehealth changes affect you?

The federal government shut down on October 1, 2025, and the Medicare telehealth flexibilities lapsed. Geographic restrictions returned, patients can no longer receive covered telehealth at home, audio-only services expired, and the hospital-at-home program lapsed.³

For a pure cash-pay clinic, that changes nothing about how you are paid. What it can do is create noise in your inbox and your comments. Patients will read "telehealth ends" headlines and ask if your service is affected. A short, calm line on your FAQ page solves that: say you are a cash-pay service and that these Medicare changes do not apply to your program, if that is true for you.

If you accept Medicare for any service, treat this as a billing issue to review with your biller or counsel.

One more date: controlled substances

If you prescribe any controlled medication by telehealth, note that the DEA and HHS extended their telemedicine prescribing flexibilities through December 31, 2025, as announced in November 2024.⁸ My earlier note on the extension through 2025 has the background. Check for any new action before year-end.

Where does compounding stand?

The FDA declared the semaglutide shortage resolved on February 21, 2025. Its compounder page then lays out the wind-down: shortage-era enforcement leeway for tirzepatide ended in March 2025, for semaglutide from compounding pharmacies in April 2025, and for outsourcing facilities in May 2025.⁴

Holland & Knight summarizes the practical effect (the earlier shortage-over note has the history): with the shortage over, standard rules apply, and compounding of these drugs is limited to 503A pharmacies working from valid patient-specific prescriptions.²

What price anchor are patients bringing in?

On March 5, 2025, Novo Nordisk launched NovoCare Pharmacy with all Wegovy doses at $499 per month for cash-paying patients.⁵ That number sits in patients' heads. Your offer is compared with it whether you like it or not.

The pricing picture also got messier in June, when Novo Nordisk ended its collaboration with Hims & Hers, saying the company sold "illegitimate, knockoff versions of Wegovy," according to CBS News. It was less than two months after the partnership was announced.⁶

The takeaway is not a verdict on any company. It is that brand-name and compounded offers are being publicly contrasted, and regulators are reading the same pages patients are.

How should you talk about price and value right now?

With a $499 brand anchor in the market, "cheaper" is a weak and risky headline. It is weak because someone can always undercut you. It is risky because price comparisons drift into claims about what the cheaper product is.

A stronger story is about what the patient actually gets: the clinician time, the follow-up cadence, the support when something feels off, the clarity about what is in the box and where it came from. Those are facts about your service you can document. They also age better than a price, which can change in a week.

Write that story in plain words on your pricing page, then check each sentence against the question the FDA letters raised: does this imply a sameness or a benefit I cannot support?

What about subscriptions and cancellation?

The Eighth Circuit vacated the FTC's click-to-cancel rule on July 8, 2025. The rule's requirements are gone, but the Restore Online Shoppers' Confidence Act, Section 5 of the FTC Act and state auto-renewal laws still apply.⁷ If you run a membership, a clear price, a clear renewal term and a simple way to cancel remain the safe path. See Click-to-Cancel Was Vacated for the build-it-anyway case.

Q4 priorities for a cash-pay clinic

The noise list

Everything else this quarter is worth knowing and not worth acting on today: opinion pieces on future policy, speculation about drug pricing, and every thread that starts "sources say." Check back when there is a date, a rule or a letter. Until then, your best use of October is fixing the pages you already control. I would rather see a clinic with clean, boring copy than one with a brilliant headline and a warning letter. How I work with clinics on the funnel side is on my telehealth page.

Keep building.Ekai