By HealthDataConsortium.org Research Team
Short answer: If a course ad makes health statements, treat them as claims you can check, and remember that a course is education, not clinical care. Before you pay, fill in a six-row card: who made it, what evidence it cites, what it costs in total, whether it renews, how you cancel, and who handles refunds and support. If you cannot fill a row from the ad, the checkout page, or the terms, that gap is useful information.
What this checklist covers, and what it does not
This guide helps you read an ad and a checkout page more carefully. It does not tell you whether any particular course works, and it does not replace advice from a licensed clinician or a lawyer. A course that discusses sleep, memory, nutrition, or stress may be interesting, but it is not a diagnosis or treatment, and nothing in an ad should change how you manage a health condition without talking to your own clinician.
HealthDataConsortium.org is an independent publication. This article has not been clinically or peer reviewed, and it contains no affiliate links.
The claim-and-checkout card
Copy these six rows into a note and fill them in before you enter payment details. Use the ad, the checkout page, and the terms of sale.
- Author identity.
- Ask: Who created the course, and who is the person speaking in the ad? What credentials are claimed?
- Good sign: A named person or company, credentials you can confirm with the body that issues them, and a plain statement of any paid or business relationship.
- Warning sign: A title like “doctor” or “leading expert” with no way to check it. FTC staff guidance says an expert endorser should actually have the qualifications presented, and that a material connection, such as a paid role with the seller, should be clearly disclosed.
- Citations.
- Ask: What exactly is claimed, and which studies are cited for that exact claim? Can you open the study itself, not just a summary?
- Good sign: A citation that matches the product, the outcome, and the kind of people the ad is aimed at.
- Warning sign: Lab-coat imagery, scientific-looking graphics, or phrases like “clinically tested” with nothing you can look up. FTC staff guidance notes that images and design can imply a claim of scientific proof, and that the overall impression counts, not only the individual sentences.
- Total cost.
- Ask: What will I pay in the first period, with every add-on I accept, plus any later charges and taxes?
- Good sign: The full amount is visible before you enter card details.
- Warning sign: A low headline price with optional extras or later charges that appear only in the terms.
- Renewal.
- Ask: Does this renew automatically? What is the price after any trial or intro period, how often is it charged, and when is the first charge?
- Good sign: The renewal terms are shown clearly before you provide billing information, and you agree to them separately.
- Warning sign: Renewal terms found only after checkout or only in small print.
- Cancellation.
- Ask: How do I cancel, and is it as easy as signing up? Will I get written confirmation?
- Good sign: A clear cancel option in your account or a plain contact route, with a confirmation message.
- Warning sign: Having to find a phone number, wait on hold, or click through many screens just to stop charges.
- Support and refund route.
- Ask: Who actually processes refunds, the seller or a payment platform? What is the window, and how do I contact them?
- Good sign: A named company, a working contact, and a stated refund window you can copy into a calendar reminder.
- Warning sign: No named business, no contact before purchase, or a refund path that is hard to find.
How to weigh the evidence an ad points to
Not all support for a claim counts the same. FTC staff guidance on health-product advertising treats these kinds of support differently:
- Well-run human trials with a comparison group. The guidance treats randomized, controlled human trials as the most reliable form of evidence for health benefit claims. It looks for a control group, random assignment, blinding where possible, results that differ meaningfully from the control group, and a benefit that matters in real life.
- Observational studies. These can show that two things go together, but the guidance says they do not prove one causes the other.
- Animal and lab-dish studies. These can offer background, but the guidance says they are not enough on their own to support a health claim in people.
- Testimonials and customer surveys. The guidance says these are never enough to support a claim about effects, even when the experiences are genuine. It also says a “results not typical” note does not fix a testimonial that suggests unusual results.
- General public-health advice. The guidance says a general recommendation from a medical organization does not by itself show that a particular product delivers a benefit.
Two more checks: vague words such as “may,” “helps,” or “promising” are not treated as adequate qualifiers, and being published in a journal is not proof of quality. Also remember this is FTC staff business guidance, not a law, and it does not give advertisers a safe harbor.
Worked example 1: matching the claim to the evidence
The FTC guidance includes two illustrative hypotheticals about brain-training products. They are teaching examples, not real ads, and they say nothing about whether any real product works.
- The ad cites a respected institution. In the first hypothetical, an online brain-training program runs a radio promotion repeating an accurate recommendation from a well-known medical institution that regular mental stimulation is good for memory. The guidance says that recommendation does not support a claim that this specific program improves memory. The seller would need sound human research on the program itself, using suitable memory measures.
- The ad cites a study that tested something narrower. In the second, an ad for brain-training software says it is “clinically proven to improve memory,” but the study only measured working memory on three lab tasks. The guidance says that does not back a general memory claim, because other types of memory, such as remembering where you left your keys, were not tested.
On your card, this is what the Citations row catches. Write down the claim in the ad's words, then write down what the cited study actually measured, in whom, and for how long. If those do not match, say so in your notes before you buy.
Worked example 2: filling in the cost rows with real published figures
Our May 11, 2026 review of an online income course is not about a health course, so it makes no health claims. It is useful here because it applies the same cost steps to a real checkout. As published in that review, the base course is a one-time $67.00 payment with no recurring charge stated at the base level, and three optional add-ons are priced at $39, $24, and $95. The review says the add-on prices were confirmed through secondary research rather than the checkout itself. The refund window is 60 days, handled through the payment platform rather than the seller.
- Base purchase only: $67.00.
- Base plus every optional add-on: $67 + $39 + $24 + $95 = $225.
- Renewal row: none stated at the base level, so the card entry is “one-time payment.”
- Refund row: 60 days, through the payment platform, so the card entry should name that platform and its support contact.
The takeaway is the method, not the numbers. The same product can cost $67 or $225 depending on what you accept at checkout. Those figures come from our earlier review and may have changed, so confirm current terms on the live checkout page before relying on them.
What the rules say about recurring charges (checked October 2, 2026)
This is general information, not legal advice, and rules in this area are changing.
- A federal law still applies. The Restore Online Shoppers' Confidence Act covers online offers where the seller treats your silence as consent to keep charging you. A law-firm summary describes three conditions: clear disclosure of material terms before collecting billing information, your express informed consent before charging, and a simple way to stop recurring charges.
- The 2024 “click-to-cancel” rule is not in effect. A federal appeals court vacated it on July 8, 2025, on procedural grounds. A law-firm summary notes that this did not remove the FTC's authority under the statute above or under Section 5 of the FTC Act.
- New rulemaking has started, but it is early. On March 11, 2026, the FTC asked the public for comment on whether to amend its negative option rule, including whether to adopt parts of the vacated 2024 rule. A law firm's March 2026 summary called this the first step and expected a final rule to be years away. We did not check for later steps, so look at the FTC's website for current status.
- State laws vary. Some states have no specific automatic-renewal law, some cover only certain transactions, and some have comprehensive rules. California is the best-known example. Your state attorney general's consumer protection office can tell you what applies where you live.
- Cancellation problems draw enforcement. In September 2025 the FTC described a settlement with an education technology company. The FTC alleged the company failed to provide a simple way to cancel recurring charges and kept charging some people after they completed its cancellation process. The company agreed to pay $7.5 million to affected consumers.
If you were charged and want out
- Save evidence first. Take screenshots of the ad, the checkout page, and the terms, and keep your receipt and order number.
- Cancel through the seller's stated route. Do it in writing or through your account so there is a record, and keep the confirmation.
- Request the refund where the terms say to. That may be the seller or the payment platform. State your order number, purchase date, and the refund window you are relying on.
- Dispute with your card issuer if needed. Many issuers have a dispute process, but deadlines are set by your issuer and card agreement, so check them soon. Our guide to online course consumer protections walks through refund steps on common payment platforms, though it focuses on income courses.
- Report misleading ads or billing practices. You can file at ReportFraud.ftc.gov, and you can also contact your state attorney general.
Who should get professional advice
- A licensed clinician, if a course's advice touches a symptom, a condition, a medication, or a change in how you eat, exercise, or sleep. A course is not a substitute for care.
- A consumer protection attorney or legal aid office, if a large charge is disputed, if you are told you cannot cancel, or if you think a contract term is unfair.
- Your card issuer or bank, for questions about disputing a specific charge.
What to do next
Before your next purchase, fill in the six-row card. If any row is blank, find the answer first or wait. If you are already enrolled, check your account today for the renewal date and the cancel route, and put the refund deadline in your calendar.
Sources opened on October 2, 2026
- FTC, Health Products Compliance Guidance: claims, evidence, testimonials, endorsers, and disclaimers.
- FTC, request for public comment on negative option marketing practices (March 11, 2026): status of new rulemaking.
- FTC Business Blog, subscription services and the Chegg settlement (September 15, 2025): cancellation practices.
- Holland & Knight, The FTC and Consumer Online Transactions (April 8, 2026): summary of the statute's three conditions (law-firm source).
- Kirkland & Ellis, FTC Restarts Subscription Rulemaking (March 19, 2026): vacatur, rulemaking timeline, and state laws (law-firm source).
- HealthDataConsortium.org, Push Button System review and Online Course Consumer Protections: the site's earlier pages.
HealthDataConsortium.org is an independent analytical publication. This article is for information only and is not medical, legal, or financial advice. It has not been clinically or peer reviewed. Rules and company terms change, so confirm current terms before you buy.

