How new FTC “Click to Cancel” rule affects your patient subscriptions

With the new year comes new regulations. This January, the Federal Trade Commission's (FTC) amendment to its Negative Option rule features a new section, known as the “click to cancel” rule. This change is intended to protect consumers from subscription services that make cancellation unnecessarily difficult. 

On the surface, this rule seems like it could be detrimental to your discount dental care plan. However, there’s good news! The “click to cancel” portion of the rule does not apply to your subscription service with Subscribili, since your Subscribili plan is likely not considered  a “subscription” under the FTC’s definition. 

There are a few things you should know, however. 

What you need to know about the Negative Option rule and your dental care subscription 

The Negative Option rule was created back in 1973 to regulate the way subscription services conducted cancellations. It’s seen many iterations over the years, but its 2025 update includes three components you should be familiar with. 

1. The Click to Cancel Rule: This rule requires subscription services to allow consumers to cancel the same way they signed up. So, the “click to cancel” nickname doesn’t encompass the breadth of the rule. 
2. Striking annual cancellation reminders: Previous iterations of the rule required subscription plan providers to remind their subscribers how to cancel prior to automatic renewals. In 2025, the FTC has removed this requirement. Now, you only need to remind subscribers that their subscription will renew on a particular date–but you don’t have to include instructions on how to cancel their plan. Subscribili automatically sends these reminders prior to renewal, giving patients plenty of time before they are charged.
3. Allowing providers to share reasons to keep an existing agreement before canceling: Before this update, providers were not allowed to offer reasons a subscriber might want to keep their plan in place after a consumer requested to cancel. Now, you can ask patients if they want to hear options to modify instead of canceling and share more about the benefits they’ll lose upon cancellation–encouraging them to stay on the plan. 

Talking to patients about canceling their subscription 

Overall, cancellation rates for patients using a Subscribili care plan are low. But life happens sometimes and patients still need to cancel on rare occasions. When a patient approaches your office about canceling their plan, you should provide them with clear and truthful information about what that means. 

Communicating cancellation fees

This depends on how your office chose to set up your subscription plan, but most practices’ plans are not a true subscription. In a true subscription model, consumers are making a monthly payment for services that will be accessed that same month; think about a gym membership or a Netflix subscription. But with Subscribili subscription  plans, most offices charge a monthly fee for annual benefits: like 2 exams, bitewings, and bi-annual cleanings. If a patient cancels their service 3 months in, but has received nearly their full annual allotment, they likely have not paid enough to cover the cost of their care. 

That’s why most offices require a Usual and Customary Rate (UCR) fee or the remaining balance of their term. This is allowed under the FTC rules, but MUST be specified in the initial agreement when a patient signs up for their subscription. Be sure to review the policies specific to your practice and contract with patients! 

Remind a patient of the value they miss 

Per the FTC rules, you are now allowed to communicate the value the patient will lose when they request to cancel their memberships. 

Take a look at their benefits dashboard in Subscribili. Identify what they have already used and share their cost savings based on your typical fee schedule. If they still have outstanding care in their treatment plan, let them know much more will it cost when they no longer have their subscription plan in place.

Offer alternatives

Sometimes, a patient may approach you to cancel their plan, but a complete cancellation may not be necessary. If your practice offers lower-tier options, you can present these to the patient as well–ensuring they find a plan in their budget but still keep some value. 

Subscribili is here to support you

Though this particular Click to Cancel rule generally doesn’t affect your subscription plans, the team at Subscribili is still here to support you! We can help coach your staff on these conversations and, in some cases, can even speak directly with patients on your behalf. 

If you have further questions or want to learn more about how to handle cancellations in the platform, you can reach us at support@subscribili.com.