I don't see what the issue is here really. If you are calling the therapist to get information from them without permission, that will simply not be given and most people know that so I can't imagine people calling to do that. But I can imagine lots of reasons why someone would put in a call--to express a concern, to provide some information that might be important, to give a point of view that may need to be considered....

The therapist is under no obligation to pay any attention to such a call. Some therapists appreciate such calls. Some use it in session to check in with the client before making any evaluation of what it means. There are all kinds of variations that are possible. To just say hands down it is inappropriate sounds odd.