Dispute drivers in telehealth, supplements, and fitness — including how HIPAA affects what you can and can't submit.
Health and wellness merchants — spanning telehealth platforms, supplement and nutraceutical companies, gyms and fitness studios, and fitness apps — face a moderate dispute rate of 0.9%, placing them near the Visa standard monitoring threshold. The defining characteristic of this vertical is not dispute volume, but regulatory complexity.
HIPAA restrictions create a unique constraint on dispute responses: health-related data that would be highly persuasive in a standard dispute context may be legally off-limits to include without explicit patient authorization. Telehealth platforms in particular must carefully navigate what evidence they can submit, and often find that their most probative documentation cannot be used without triggering compliance concerns.
Supplement companies face a high "not as described" dispute rate driven by disappointed customers who expected clinical results from non-clinical products. Gyms and fitness studios face cancellation-related disputes similar to SaaS, while telehealth platforms deal primarily with "service not received" claims for cancelled or no-show appointments.
The distribution of dispute codes in health and wellness reflects the diverse sub-verticals: supplement companies drive the not-received and not-as-described codes; telehealth platforms drive fraud and not-received codes; fitness businesses drive the cancelled recurring codes.
| Code | Network | Description | Share of Disputes |
|---|---|---|---|
| Visa 13.1 | Visa | Merchandise / Services Not Received | 28% |
| MC 4853 | Mastercard | Not as Described | 22% |
| Visa 10.4 | Visa | CNP Fraud | 19% |
| MC 4841 | Mastercard | Cancelled Recurring Transaction | 16% |
| Amex F29 | Amex | Card Not Present Fraud | 10% |
| Other | Various | Various | 5% |
The intersection of HIPAA and chargeback dispute response is one of the least-discussed compliance topics in the health technology space, and one of the most practically important. Getting it wrong can create regulatory exposure that significantly exceeds the value of the disputed transaction.
You cannot include protected health information (PHI) — diagnoses, treatment records, prescription details, clinical notes, or any information that links an individual to their health condition — in a chargeback response without explicit written patient authorization under HIPAA's Privacy Rule. This applies even if the information would be decisive in winning the dispute. Telehealth platforms that submit clinical records without proper authorization risk HIPAA enforcement in addition to the chargeback loss. Consult your compliance team before submitting any health-related records.
The practical implication is that telehealth platforms must build a second tier of dispute evidence — documentation that proves the service occurred without revealing what the service contained. This is not as difficult as it sounds:
Supplement and nutraceutical companies face a distinctly high "not as described" dispute rate that is driven by a fundamental mismatch between marketing claims and regulatory limitations. Customers who purchase supplements expecting clinical results — weight loss, muscle gain, specific health outcomes — and don't achieve them frequently dispute the charge on the grounds that the product didn't do what was advertised.
The core defense strategy has four components, each of which must be documented before a dispute is filed:
Product description accuracy: Your dispute response must show that the product description at the time of purchase matched what was actually in the product. Retain screenshots of product listing pages dated to the transaction date. If your marketing copy has been updated since the sale, you need records of what it said at the time.
No prohibited health claims: If your marketing materials contain implied or explicit disease claims that violate FTC or FDA guidance, a cardholder disputing on "not as described" grounds may receive sympathy from arbitrators who view the marketing as misrepresentation. Audit your product pages for compliance with FTC guidelines on health claim substantiation.
Clear refund policy disclosure: A prominently displayed, clearly worded refund policy that was visible at checkout and acknowledged by the customer is your strongest defense against "not as described" disputes for products that were accurately described but didn't perform to the customer's expectations.
Third-party lab results: For "not as described" disputes that specifically allege the product didn't contain what the label claimed, current certificate of analysis (COA) documentation from a third-party lab showing the product matches its label claims is the definitive rebuttal.
Gym and fitness studio disputes follow patterns almost identical to the SaaS and subscription vertical, with one additional complication: state consumer protection laws in several jurisdictions specifically regulate gym membership cancellations, creating a regulatory layer above and beyond network rules.
The dominant dispute categories for fitness businesses are cancelled memberships (codes 4841 and 13.6), annual renewal disputes, and class or appointment no-shows. The defense strategy is fundamentally the same as subscription businesses: comprehensive cancellation logging is the highest-impact operational investment.
State-specific gym regulations in California, New York, and a number of other states mandate specific cancellation procedures, response timelines, and refund obligations. A dispute response for a gym membership cancellation must comply with both network dispute rules and applicable state consumer protection statutes. If your cancellation procedure doesn't meet state requirements, winning the network dispute may not protect you from a state consumer complaint.
These four evidence types are the core of a HIPAA-compliant telehealth dispute response. Each can be submitted without triggering PHI disclosure concerns when they contain only the listed data elements and no clinical content.