On April 11, 2025, the FCC’s updated TCPA consent revocation rules will reshape the way healthcare organizations communicate with patients. In our recent webinar, “When in Doubt, Opt Them Out, Upcoming TCPA Changes and How to Adapt” mPulse’s TCPA subject matter experts—Brendan McClure, Chief Marketing Officer, SriVani Gandhi, Director of Content and Creative Services, and Kyle Blanchard, Director of Product Management—explored the regulatory changes, technology challenges, and best practices that can help organizations both stay compliant and enhance patient engagement.
Here, we’ll dive deep into what Brendan, SriVani, and Kyle had to say, including what these changes mean, why they matter, and how you can start preparing today.
The Four Pillars of the April 11th Revocation Rules
The new FCC rules are designed to strengthen consumer control over automated communications. While this provides greater transparency and protection for consumers, this also means healthcare organizations must rethink their engagement strategies to maintain compliance without losing their ability to connect with their members.
Let’s level set by going through the four broad changes brought about by the new consent revocation rules and digging into what plans can do to adjust:
1. Broader Scope of Opt-Outs and Cross-Channel Opt-Out Enforcement
What’s Changing:
Traditionally, consumers could opt out of telemarketing messages only. With the new rules, an opt-out now extends to all automated messages—informational texts, appointment reminders, and prescription notifications—that fall under the TCPA’s ambit, including those messages that fall under the healthcare exception.
And not only are they opting out of all programs and message types, but now the revocation rules clarify that if a consumer opts out on one channel (e.g., SMS), they are also opting out of all other channels too, such as IVR (interactive voice response) calls and pre-recorded voice messages (previously an opt-out request only applied to the channel it was received).
Why It Matters & What To Do:
These first two changes change means that a simple “STOP” response no longer only halts sales calls. It also stops all automated outreach from your organization – and across all channels. While this strengthens consumer rights, it poses a challenge for healthcare organizations that rely on these communications to deliver critical information and maintain relationships with their members.
There are best practices plans can implement to adjust to this new rule, however. First, proactively inform your members about the result of opting out of a program before they opt out. A simple clarification message providing context to the member can be delivered as a message or audio message in either a SMS or IVR program.
If they do end up opting out, though, all is not lost. Senders have five minutes to clarify the opt-out request. Take advantage of this with your members and give them a chance to revise their request if an opt-out of all communications was not what they intended (see below for what this might look like).
A recent survey conducted by mPulse on 1,000 US residents found that 76% of consumers said that if they knew that opting out from one communication channel from your health insurance plan would remove you from all future communication channels, that would change how they managed their communication preferences. This tells us the customer wants to have more control over their communication preferences and that it’s important plans keep this in mind and give your members a chance to make their intentions clear.
2. Shortened Compliance Window: From 30 Days to 10
What’s Changing:
The timeframe for honoring an opt-out request has been shortened from 30 business days to just 10 business days.
Why It Matters & What To Do:
With a shorter window to process opt-outs, healthcare organizations need well-integrated seamless systems in place to update data across vendors and internal teams. If not, they risk falling out of compliance and facing potential regulatory issues.
To stay on top of this, having a centralized data management system or an integrated Health Experience and Insights platform is key. This ensures that when a member opts out, the update happens instantly across all channels, preventing any accidental messages and keeping communication smooth and compliant.
3. Expanded Language and Methods for Opting Out
What’s Changing:
Beyond standard keywords like “STOP” or “END,” the new rules require organizations to respect a broader range of consumer expressions—even variations, misspellings, or alternative phrases (including those in different languages or even emojis). This means the way a consumer can opt out is more varied and plans must adapt to that to stay in compliance.
Why It Matters & What To Do:
This expansion requires an upgrade from keyword-based systems to more advanced Natural Language Understanding (NLU) solutions. If a response from a member is in another language (ex: “No mas”) or includes other unexpected phrases (ex: “take me off your list”), you are still responsible for respecting that customers request. Technology like NLU helps you accurately interpret diverse opt-out requests is becoming fast necessary to stay compliance with the TCPA and ensure every consumer’s intent is recognized and acted upon.
For IVR systems that rely on pre-recorded messages, incorporating real-time voice recognition poses technical and legal challenges, especially with the new requirement to include opt-out instructions immediately after greeting the member. The best plan is to enhance your IVR systems with robust voice recognition and speech-to-text capabilities. This ensures that consumers who speak their opt-out commands—even in less conventional language—are correctly identified and processed.
4. Reduce Abrasion with Orchestration
The starting point will always be to avoid the opt-out to begin with. How can plans do that? Through smart orchestration that keeps outreach helpful, not overwhelming. Instead of sending members multiple messages at once from multiple departments and programs, intelligently prioritize what’s most important—like a medication refill reminder—while saving less urgent ones, such as a flu shot notice, for later.
A strong partnership with your engagement vendor and use of effective technology, such as a Health Experience and Insights platform with an integrated data layer, will help you space out communications preventing fatigue and frustration – and ultimately, opt-outs. These platforms can help you use data to make the right decisions at scale.
Looking Ahead: Embracing Change for Better Engagement
The updated FCC TCPA consent revocation rules present both challenges and opportunities. On one hand, the broader scope and accelerated timelines require healthcare organizations to reevaluate and often overhaul their current communication systems. On the other hand, these changes pave the way for more patient-centric communication strategies that honor consumer preferences and build trust.
By investing in advanced technology—such as NLU-driven opt-out management, a Health Experience and Insights platform, and enhanced IVR capabilities—healthcare organizations can ensure compliance while also reducing unnecessary opt-outs. Moreover, leveraging multi-channel strategies allows organizations to maintain critical communication with patients without overstepping regulatory boundaries.
If you’re looking to learn more about these changes or need guidance on revamping your communication strategy, we invite you to watch the full webinar recording and connect with our team at mPulse. Together, we can navigate this evolving landscape and continue to deliver essential healthcare communications in a compliant and consumer-friendly manner.
For further insights, resources, or to schedule a consultation, please contact us at mPulse or subscribe to our newsletter for ongoing updates on TCPA compliance and healthcare engagement strategies.
The content on this blog is provided for general informational purposes only and does not constitute legal advice. You should always consult with a licensed attorney regarding any legal questions or concerns you may have regarding the FCC and TCPA and laws therein.
