If it isn't already a requirement, I'd suggest pushing the FCC to require SPOT to forward SOS calls to the appropriate authorities with or without subscription
The problem then is that nobody would ever buy a subscription and SPOT would go bust. I would like to be treated the same with or without medical insurance but it ain't going to happen.
They would still have the income from the sale of the device, plus the subscription for those who want "OK" messages. It also might give them more of an incentive to improve text messaging...maybe partner with Sirius for the downlink if they don't have coverage themselves.
The analogy is more like someone refusing to answer your call for help because you're broke. That used to happen with private fire departments, years ago, but now with or without insurance, you'll get help...ambulance too, if you need it.
A requirement to provide some sort of public service in exchange for the use of the public airwaves has precedent - public service announcements, civil defense and later emergency alert system for broadcasters, and enhanced 911 for cell phones.