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Med spa memberships and treatment packages: pricing basics and the rules on renewals

A small team at a med spa and aesthetic clinic in a short morning huddle

Memberships and treatment packages can give a med spa or aesthetic practice steadier income and give patients a clearer way to plan their care. They also bring rules: automatic renewals, cancellation, gift cards and cost estimates all have legal requirements, and a package should never decide a patient’s treatment plan for them. This guide is for owners and managers setting up or reviewing memberships and packages. It covers the basic structures, how to price them, and the rules to check with counsel.

  1. SearchAn adult looks for care near them.
  2. Your pageWhat you treat, who sees them, one way to book.
  3. Call or formThey call or send a request.
  4. Front deskBooks the visit and never guesses a cause.
  5. Clinical teamThe clinician decides the plan.
How a new patient request reaches your practice.

1. Know the three common structures

  • Monthly membership: a recurring charge that gives members a benefit, such as a set amount toward treatments each month or member pricing on services and products.
  • Prepaid treatment package: a fixed number of sessions of one treatment, paid in advance, often for treatments that are usually done as a series.
  • Gift cards and gift certificates: a prepaid amount someone buys for another person to use at your practice.

Each one creates different obligations. A membership is usually an automatic renewal. A package is a prepayment for future care. A gift card falls under federal gift card rules.

2. Price from your own numbers

Start with what a treatment costs you to deliver: provider time, product, room time and supplies. Then decide what the membership or package is for. Is it to spread income over the year, to fill quieter days, or to reward patients who already come back? Price it so that a fully used membership still covers your costs, because some members will use every benefit. Write down what happens to unused monthly credits (do they roll over, and for how long?) before you launch, not after the first complaint.

Keep the offer simple enough to explain at the front desk in a sentence or two. If staff cannot explain it, patients may not understand what they are agreeing to.

3. Automatic renewals: the federal rule that applies now

If patients can sign up for a recurring membership online, the federal Restore Online Shoppers’ Confidence Act (15 U.S.C. 8403) applies. It makes it unlawful to charge a consumer through an online negative option feature unless the business:

  1. clearly and conspicuously discloses all material terms of the transaction before obtaining the consumer’s billing information,
  2. obtains the consumer’s express informed consent before charging their card or account, and
  3. provides simple mechanisms for the consumer to stop recurring charges.

You may have heard of the FTC’s 2024 “click to cancel” rule. The U.S. Court of Appeals for the Eighth Circuit vacated that rule on July 8, 2025, so it is not in effect. ROSCA, the FTC Act and state laws still apply, and the FTC may propose a new rule, so check the current status with counsel.

4. State automatic renewal laws

Some states add their own requirements. California’s automatic renewal law (Business and Professions Code section 17602), for example, requires a business to obtain the consumer’s affirmative consent to the renewal terms and to provide an acknowledgment with the terms, the cancellation policy and how to cancel. When the consumer signed up online, it must let them cancel online, through a prominent link or button or a ready-to-send termination email. Other states have their own versions, so ask counsel which apply where your patients live.

In practice, that means:

  • Show the price, billing date, what is included, the minimum term (if any) and how to cancel before you take card details.
  • Use a separate, unticked box or a clear action for agreeing to the renewal terms.
  • Send a written confirmation with the terms and how to cancel.
  • Make cancelling at least as easy as joining, and record when a member asks to cancel.

5. Prepaid packages: plan for the patient who stops

Patients stop a series for many reasons: a side effect, a change in their health, a move, or a provider’s advice that more sessions will not help. Decide in advance and write into the package terms what happens to unused sessions: refund, credit toward another treatment, or transfer. State consumer protection laws on prepaid services and refunds vary, so check them with counsel. A clear policy, explained before payment, gives the patient and the practice an answer when it happens.

A package does not replace the clinical decision. Each session still needs the provider’s assessment, and a patient who is not a good candidate should not be sold a series. For self-pay patients, health care providers also have duties under the federal good faith estimate rule; 45 CFR 149.610 allows a single estimate for recurring services that covers no more than 12 months. Our guide on consultation to treatment explains the estimate rules.

6. Gift cards

Federal rules in 12 CFR 1005.20 cover gift certificates and store gift cards. A card generally cannot be sold with an expiration date unless, among other conditions, the funds do not expire for at least five years, and the rule limits dormancy, inactivity and service fees. State laws may add their own rules. If you sell gift cards for treatments, state clearly that the treatment still depends on a consultation and the provider’s assessment, and what happens if the recipient is not a candidate.

7. Present memberships honestly

  • Do not promise results, and keep any claims about treatments accurate and supported; our guide on getting more aesthetic patients covers advertising claims.
  • Do not use countdown deadlines or pressure to push a medical decision.
  • If you offer payment plans alongside memberships, explain them plainly; see patient financing for elective treatments.
  • Train the front desk to explain cancellation as readily as joining.

Where MediLeadGen fits

A membership program still depends on new patients joining. MediLeadGen sends practices requests from patients interested in cash-pay elective treatments, each sent to one practice with consent naming that practice, at a fixed price per delivered request. Requests arrive in a login-protected inbox where your team marks them new, contacted, consult set or not a fit.

See how it works for practices

Questions practices ask

What rules apply to med spa memberships that renew automatically?

For online sign-ups, the federal Restore Online Shoppers’ Confidence Act requires clear disclosure of all material terms before taking billing information, express informed consent before charging, and a simple way to stop recurring charges. Some states add their own automatic renewal laws.

Is the FTC click-to-cancel rule in effect?

No. The Eighth Circuit vacated the FTC’s 2024 rule on July 8, 2025. ROSCA, the FTC Act and state laws still apply, and the FTC may propose a new rule, so check the current status with counsel.

How should a practice price a membership?

From its own costs: provider time, product, room time and supplies. Price so that a fully used membership still covers costs, and decide in advance what happens to unused monthly credits.

What happens to unused sessions in a treatment package?

Decide before you sell it and put it in the terms: refund, credit or transfer. State rules on prepaid services and refunds vary, so check with counsel.

Can med spa gift cards expire?

Federal rules at 12 CFR 1005.20 generally do not allow a gift card to be sold with an expiration date unless the funds last at least five years, among other conditions. State laws may add their own rules.

General information for practice teams, not legal advice. Membership, renewal, refund and gift card rules vary by state and change over time; check with counsel. Last reviewed October 2026.

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