Definition
The Reassigned Numbers Database (RND) is the FCC-established database that callers can query to learn whether a telephone number has been permanently disconnected, and so may have been reassigned, since a given date, with a TCPA safe harbor for callers who rely on it.
Numbers change hands constantly: a patient drops a line, the carrier holds it through an aging period, and it is reassigned to someone who never agreed to the caller's calls. Under the TCPA, consent comes from the current subscriber, so calling a reassigned number can be a violation even when the original consent was valid. The D.C. Circuit set aside the FCC's earlier one-call safe harbor for reassigned numbers in ACA International v. FCC (2018), and the FCC adopted the RND in December of that year as a replacement.
The database became available to callers in November 2021 and is administered by Somos under FCC oversight. Voice providers report permanent disconnections monthly. A caller submits a number with the date it obtained consent, and the database answers whether the number has been permanently disconnected since then. A caller that queries properly and receives a "no" is protected from TCPA liability if that answer turns out to be wrong.
Wrong-number calls are a live litigation risk in healthcare: OptumRx's $1.86M Patterson v. OptumRx settlement (March 2026) involved medication-adherence calls placed to wrong numbers. Checking for reassignment before a campaign runs is part of the data hygiene that keeps consent attached to the right person.
How Consig handles it
Consig verifies identity with passkeys, device biometrics, or one-time passcodes before any health information is discussed, so a call that reaches the wrong person does not disclose protected details. Its compliance engine enforces the relevant federal and state calling rules on each call.