Telehealth Growth Desk: The 2025 Outlook

If I had to bet on what breaks first in a cash-pay telehealth business this year, I would not bet on demand.

What breaks is the thing the business was quietly standing on: a product that is allowed to be compounded, a prescribing rule that is allowed to be remote, an ad platform that is allowed to optimize on lower-funnel events. All three are moving at the same time.

Telehealth Growth Desk is where I turn news into operating decisions. This is education about public information, not legal advice. Have a healthcare attorney review your own compliance, prescribing and advertising.

The clinics that keep growing in 2025 will be the ones that build on the part of the business that does not expire.

What is force one: compounded GLP-1s winding down?

A shortage that made one business model possible has ended on paper, with dates attached.

What changed

The FDA first said on October 2, 2024 that the tirzepatide shortage was resolved and noted that, after a shortage ends, the agency generally considers the drug commercially available for 503A purposes and that 503B outsourcing facilities cannot make drugs that are essentially copies of an approved drug unless it is on the shortage list.¹ The decision was sent back for reevaluation on October 22, and on December 19 the FDA again determined the shortage resolved.¹²

Reports on that order give 503A compounders a 60-day enforcement discretion window through February 18, 2025, and 503B outsourcing facilities a 90-day window through March 19, 2025.² Semaglutide is assessed drug by drug and remained on the shortage list at the time of that summary.² I covered the full timeline in Tirzepatide Shortage Over, Now What?.

What it changes for a clinic

If a meaningful share of your revenue and your marketing depends on a compounded product, your offer has an expiration date. Supply from the brand side has been expanding too. Lilly announced single-dose Zepbound vials for self-pay through LillyDirect on August 27, 2024, for patients with a valid on-label prescription.³

What to do

What is force two: the DEA runway?

A year of visibility, not a permanent answer.

The facts

On November 15, 2024 the DEA, jointly with HHS, extended current telemedicine flexibilities through December 31, 2025.⁴ The Federal Register notice says a DEA-registered practitioner may prescribe Schedule II to V controlled substances via telemedicine without having conducted an in-person medical evaluation, provided conditions are met, including a legitimate medical purpose, an interactive telecommunications system and compliance with federal and state law.⁵ The DEA says it is working to promulgate a final set of telemedicine regulations.⁴ My earlier note on the extension is here.

What it changes for a clinic

If you do not prescribe controlled substances, this is not your story. If you do, the date is the story. Permanent rules could look different from the flexibilities, and nothing in the notice tells us when they arrive.

What to do

Document your telemedicine process, check the state rules where your patients live, and model revenue under two scenarios: the flexibilities continue in some form, and they end or change. Build a contingency path, such as partner clinics or scheduled in-person options, before you need it.

What is force three: Meta and health data?

The platform you buy attention from is changing what it will let you tell it.

The report

Marketing Brew reported on December 9 that Meta had begun notifying advertisers about new data restrictions, set out in a November advertising policy update. Meta "may restrict the sharing of specific mid- and lower-funnel events," and optimization tools could stop working in some cases. The report says the policy takes effect in January.⁶ I audited the three layers in Meta Is Coming for Health Data. A Meta spokesperson described the aim as helping prevent advertisers from sharing sensitive information through Meta Business Tools.⁶

The regulators are in the same room

Meta is not alone in caring about this. In April 2024 the FTC finalized changes to the Health Breach Notification Rule, clarifying that it covers health apps and similar technologies outside HIPAA and that a breach of security includes unauthorized disclosure.⁷ HHS's Office for Civil Rights has said regulated entities may not use tracking technologies in ways that cause impermissible disclosures of protected health information, though a federal court vacated one part of its guidance in June 2024 and HHS said it was evaluating next steps (see HIPAA, Tracking Pixels and the Court Ruling).⁸

What to do

Audit three layers: event names, event parameters and page URLs. Strip anything that names a condition, treatment or patient relationship. Check how Meta categorizes your data sources in Events Manager, as the spokesperson advised, and decide now what you would optimize for if lower-funnel events were limited.⁶ Keep your own record of booked consults and completed visits.

This is also a business decision, not only a compliance one. A leaner data trail is easier to explain to a patient, easier to defend to a regulator and easier to carry from one ad platform to another if the rules change again.

How do the three forces interact?

Together they raise the value of a few things and lower the value of others.

The compounding risk

The risk is not any single force. It is three at once, landing on a business with no slack. A clinic that loses a product line, faces a prescribing change and has its ad optimization narrowed in the same year is a clinic that has no room to learn. So build room.

What belongs on a 2025 telehealth calendar?

Put the dates you can see on one page.

Add the quiet items

If you sell memberships or recurring plans, the FTC's October 16, 2024 negative option rule covers subscriptions and other recurring-payment programs and requires simple cancellation, clear disclosure of material terms and express informed consent before charging.⁹ Read it with your attorney and check your billing pages and cancellation flow.

What do the scenarios look like?

Plan for three, not one. These are planning tools, not predictions.

The easier case

The wind-down dates hold, the DEA flexibilities continue in some form and Meta's changes turn out narrower than feared. A clinic with a care-led offer and clean data barely notices. It simply keeps compounding its advantage while others scramble.

The base case

Compounded product ends on schedule, the DEA runway is used up without a final rule and Meta restricts some lower-funnel events. This is where most of the work in this article pays off. The clinic that has rewritten its offer, documented its process and diversified its measurement absorbs the changes in a quarter.

The hard case

Several things land in the same month. A clinic with one product line, one prescribing model and one set of ad events can lose most of its volume at once. The question to ask today is not whether the hard case will happen. It is whether you would still be in business if it did, and what you would cut first.

What mistakes will clinics make this year?

A few are predictable.

• Waiting for the final rule before doing anything. Most of the preparation is the same under every outcome.
• Treating compliance as a marketing task. Ad copy and tracking are part of it, but the clinical and legal questions belong with clinicians and counsel.
• Leaning harder on the thing that is ending. Spending more to sell a product with a reported expiry date is a bet against the calendar.
• Ignoring patient communication. Patients forgive a clear change announced early. They do not forgive finding out at the pharmacy counter.
• Measuring only inside the ad platform. If the platform's events narrow, you want your own record of what each campaign produced.

How should a clinic owner think about all this?

Calmly, in writing and on a schedule.

What I would do in the first 30 days

• Name one person who owns each force: product, prescribing and advertising.
• Get written answers from the pharmacy partner and the attorney.
• Strip sensitive detail from tracking and URLs.
• Rewrite the offer page around the care model.
• Put every date above on a shared calendar.

None of these forces is a reason to stop. They are reasons to build the part of the clinic that lasts: the clinical quality, the follow-up, the honest communication, the clean data. Do that, and 2025 is a year when disciplined operators pull ahead of the ones who depended on a single allowance.

For an outside look at how your ad account and tracking are set up, contact me.

Keep building.Ekai