The FTC and HHS sent warning letters to approximately 130 hospital systems and telehealth providers about the privacy and security risks of using online tracking technologies, such as Meta/Facebook pixel and Google Analytics, which may impermissibly disclose sensitive health information to third parties. The agencies emphasized that such disclosures could violate HIPAA for covered entities and the FTC Act for others, citing recent enforcement actions against companies like BetterHelp and GoodRx.
In-house legal teams should review all agreements where online tracking technologies (e.g., Meta Pixel, Google Analytics) are integrated, including vendor contracts with analytics providers, customer-facing terms of service or patient portal agreements, and any data processing addendums. Specific clauses to scrutinize include data sharing provisions, consent mechanisms for collecting sensitive health information, breach notification obligations, and requirements under HIPAA business associate agreements. Changes may be needed to prohibit impermissible disclosure of protected health information (PHI) to third-party advertisers, mandate explicit patient consent for tracking, update BAAs to reflect tracking risks, and revise privacy policies to disclose tracking practices transparently. State privacy laws (e.g., CCPA) may also require modifications to opt-out rights and data retention terms.
Entity
Hospital Systems and Telehealth Providers
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2023/07/ftc-hhs-warn-hospital-systems-telehealth-providers-about-privacy-security-risks-online-tracking
FTC OCR Letter Third Party Trackers 07 20 2023
https://www.ftc.gov/system/files/ftc_gov/pdf/FTC-OCR-Letter-Third-Party-Trackers-07-20-2023.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"to approximately 130 hospital systems and telehealth providers"
"Health Insurance Portability and Accountability Act (HIPAA)"
"FTC Act"
"FTC’s Health Breach Notification Rule"
"impermissibly disclosing consumers’ sensitive personal health data to third parties"
The FTC, Utah, and Nevada sued Lens.com Inc., alleging that it advertised artificially low contact lens prices while hiding mandatory checkout charges and misleading consumers about its AutoRefill subscription. The complaint seeks to stop the alleged practices; the court has not yet decided the case, and no penalty or remedy has been imposed.
The FTC issued an advance notice of proposed rulemaking seeking public comment on whether ad-optimization tools offered by online platforms may help scammers impersonate businesses and government agencies. This is a proposed regulatory inquiry, not an enforcement action against a named company; no penalty or remedy was imposed.
$2.5B
A federal court approved a revised order in the FTC's Amazon Prime case under which Amazon will accelerate and expand redress payments under the September 2025 $2.5 billion settlement, which resolved allegations that Amazon enrolled millions of consumers in Prime subscriptions without their consent and knowingly made cancellation difficult. More consumers now qualify for refunds, the maximum payment cap rises from $51 to $200, and all future payments will be distributed automatically starting October 1, 2026, with potential supplemental $149 payments by April 2027. Amazon has already issued more than $845 million in redress payments as of September 2026.
$225.0M
The FTC and the state of Washington filed a joint complaint and proposed stipulated order requiring Amway Corp. and two affiliates—World Wide Group, L.L.C. (WWG) and Leadership Team Development Inc. (LTD)—to pay a $225 million judgment, the largest monetary recovery ever obtained from an MLM in an FTC action, over allegations that they used deceptive earnings claims and unfair tactics to recruit Independent Business Owners. The complaint alleges the companies falsely promised substantial income and recruitment success, pressured IBOs to buy products they could not resell, and instructed IBOs to falsely report sales. Nearly all of the judgment will be used as redress for IBOs who lost money, and the proposed order imposes structural reforms including a 70% resale requirement, independent audits of sales records, and a ban on approved providers charging new IBOs for first-year training.
$100.0M
FleetCor Technologies Inc. (now Corpay Inc.) and its CEO Ronald Clarke agreed to pay $100 million to settle an FTC administrative action alleging the company charged small business customers hidden and unauthorized fees for fuel cards and misrepresented gas savings, fraud-control features, and fees. A federal district court granted the FTC summary judgment on all counts in 2023, and a federal appeals court upheld that judgment and the permanent injunction in 2026. The settlement funds will be used to provide redress to harmed business customers.
FTC staff published FAQs on price transparency to help the automobile industry comply with the FTC Act, reiterating that an advertised vehicle price must be the actual price any consumer can pay, excluding only government-required charges. The guidance follows warning letters the FTC sent to 97 auto dealership groups earlier in 2026 and signals continued litigation against dealers that advertise one price but charge more through undisclosed fees. No specific entity was charged and no penalty was imposed.