PHMC Ad Guidelines: Top 10 Dos And Don’ts Of Medical Advertising In Singapore

What Are the PHMC Ad Guidelines?

The Private Hospitals and Medical Clinics (PHMC) Act is a legislative framework established in Singapore to regulate the operation of healthcare institutions, including private hospitals, medical clinics, and other healthcare facilities. Among its many mandates, the Act provides comprehensive guidelines for advertising medical services, ensuring that all promotional materials maintain ethical standards and prioritise patient well-being.

This article will provide you with these key takeaways and more insights about the dos and don’ts of medical advertising adhering to the PHMC ad guidelines. 

Key Takeaways

• PHMC Act provides guidelines on how to do medical advertising properly. Some of the guidelines include the following:
• Do Use Factual and Evidence-Based Claims
• Do Not Use Offensive and Ostentatious Ads
• Don’t Use Misleading or Exaggerated Statements
• Don’t Use Laudatory Statements
• Do Highlight Verified Testimonials and Reviews
• Don’t Make Comparisons with Competitors
• Do Use Approved Medical Terminology
• Don’t Use Any Form of Promotion
• Don’t Advertise Prohibited Services and Procedures
• Don’t Forget to Include Disclaimers and Transparency

Why PHMC Ad Guidelines Matter for Medical Advertising

Legal Implications for Non-Compliance

Failing to comply with PHMC advertising guidelines can result in severe consequences for healthcare providers, including:

• Hefty Fines: Non-compliance can lead to financial penalties that strain business operations.
• License Suspension or Revocation: Repeated violations may jeopardise the institution’s ability to operate.
• Reputational Damage: Publicised breaches can tarnish a healthcare provider’s credibility, causing loss of patient trust.

Building Trust and Credibility with Patients

Adhering to PHMC guidelines is not just about avoiding penalties. It is also about building trust. Patients rely on transparent and truthful information to make informed decisions in a sensitive field like healthcare. Misleading claims or exaggerated promises can erode confidence, potentially deterring patients from seeking care.

By complying with these regulations, healthcare providers demonstrate their commitment to ethical practices, ultimately enhancing their reputation and patient relationships.

PHMC Ad Guideline 1: Do Use Factual and Evidence-Based Claims

Image source: Springer Nature Link

In healthcare advertising, the credibility of an advertisement hinges on its reliance on evidence-backed data. The PHMC guidelines emphasise this because medical claims directly impact public health and consumer trust. Unsubstantiated claims can mislead patients, creating false expectations or causing harm by promoting ineffective treatments.

Evidence-backed advertising ensures that the information shared is:

• Accurate: Representing the true efficacy, safety, and benefits of the medical service or product.
• Reliable: Supported by robust studies or clinical trials published in credible, peer-reviewed journals.
• Transparent: Providing consumers with sufficient information to make informed decisions.

Examples of Compliance

• Showcasing Clinical Trial Results: An ad for a new cholesterol-lowering medication might include a statement like: “In a double-blind clinical study involving 1,000 patients, this medication reduced LDL cholesterol levels by an average of 30% over 12 weeks.” This statement demonstrates transparency by citing study parameters and results without exaggerating the benefit.
• Using Statistics to Support Claims: An ad for a dental clinic could state: “95% of our patients reported improved oral health within three months, based on a survey conducted with 200 patients in 2023.” By quantifying the claim and referencing the sample size, the ad complies with PHMC guidelines while reinforcing trust.

Image source: Khoo Teck Puat Hospital

• Citing Research: A campaign for a weight-loss program might refer to external research: “Our approach is based on methods validated by a 2022 study published in the Journal of Nutrition.” Linking the claim to an authoritative source enhances credibility and compliance.

Best Practices

• Collaborate with Medical Professionals: Engage healthcare experts to validate marketing claims. Their expertise ensures that advertisements are not only accurate but also scientifically sound. Example: Partner with a dietitian or physician to review a weight-loss clinic’s promotional content to ensure its claims align with medical science.
  
• Conduct a Compliance Review: Before publishing an ad, have it vetted by legal and regulatory teams that are familiar with the PHMC guidelines. This step can help identify and rectify non-compliant elements.
  
• Use Authoritative Sources: Rely on trusted medical journals, government health agencies, and recognised institutions for data. Citing these sources adds credibility and ensures compliance with evidence-based standards.
  
• Avoid Ambiguity: Ensure that all data used in ads are precise and contextual. Avoid vague terms like “groundbreaking” or “revolutionary” unless supported by concrete evidence.
  
• Regularly Update Claims: Medical knowledge evolves rapidly. Periodically review and update advertisements to reflect the latest scientific understanding and maintain compliance.

PHMC Ad Guideline 2: Do Not Use Offensive and Ostentatious Ads

Image source: The Nation’s Health

The PHMC guidelines prohibit medical advertisements that are offensive, overly dramatic, or ostentatious. This regulation ensures that healthcare advertising remains professional, ethical, and aligned with Singapore’s cultural sensitivities. The goal is to prevent:

• Sensationalism: Using exaggerated visuals or claims to shock or scare consumers into seeking treatment.
• Disrespectful Content: Ads that mock or stigmatize certain medical conditions.
• Overly Glamorous Promotions: Using flashy imagery or celebrity endorsements to make treatments seem like luxury lifestyle choices rather than medical decisions.

Examples of Non-Compliant Ads

• Overly Dramatic Before-and-After Images
• • Example: An ad for a weight-loss procedure showing an extreme transformation with misleading captions like “Instant results! Look 10 years younger overnight!”
  • Why It’s a Violation: Exaggerated claims create unrealistic expectations and may mislead consumers.
• Fear-Based Marketing
  • Example: A dental clinic ad stating, “Neglecting cavities could lead to life-threatening infections—book an appointment now before it’s too late!”
  • Why It’s a Violation: While dental health is essential, the ad uses fear tactics, which are not allowed.
• Sexually Suggestive or Inappropriate Content
  • Example: A clinic advertising male enhancement treatments with provocative imagery.
  • Why It’s a Violation: PHMC guidelines require tasteful and medically focused ads.
• Celebrity Endorsements and Influencer Promotions
  • Example: A skincare clinic promoting laser treatments with a celebrity claiming, “This is my secret to flawless skin—guaranteed to work for everyone!”
  • Why It’s a Violation: Celebrity endorsements can be misleading, implying universal effectiveness.

Best Practices for Compliance

• Use Professional, Informative Language
  • Keep ad copy neutral and fact-based.
  • Example: Instead of “Transform your look instantly!” use “Our treatment supports gradual, medically supervised improvements.”
• Avoid Overly Aggressive Call-to-Actions
  • Example: Replace “Book now before it’s too late!” with “Schedule a consultation to discuss personalized treatment options.”
• Maintain Medical and Ethical Standards in Visuals
  • Use respectful, accurate imagery that represents treatments realistically.
  • Avoid shocking, exaggerated, or misleading visuals.
• Include Proper Disclaimers
  • Clearly state that results may vary.
  • Example: “Results depend on individual health conditions and treatment plans.”
• Ensure Cultural Sensitivity
  • Avoid language or visuals that could be offensive to certain communities.
  • Be mindful of Singapore’s multicultural society when creating content.

PHMC Ad Guideline 3: Don’t Use Misleading or Exaggerated Statements

Image source: Meesho

One of the most significant restrictions under the PHMC guidelines is the prohibition against misleading or exaggerated advertising. Promising guaranteed outcomes in healthcare ads is particularly problematic because medical results often vary from patient to patient. For example, claims like “Guaranteed cure for chronic back pain” or “Lose 10kg in 10 days, 100% success rate” create unrealistic expectations and can be classified as deceptive.

These pitfalls violate legal standards and can lead to a loss of trust among patients. Misleading statements can result in severe consequences, including:

• Financial penalties
• Regulatory actions, such as suspension or revocation of advertising privileges
• Reputational harm, as patients share negative experiences about unfulfilled promises

Case Study: An Example of a Campaign Penalised for Exaggeration

In 2020, a Singapore-based aesthetic clinic ran a digital campaign promoting a skin treatment. The ad claimed the procedure would deliver “instant and permanent results for flawless skin” without mentioning the variability of outcomes or potential risks.

Regulatory Response

• The authorities flagged the campaign for violating PHMC guidelines.
• The clinic was fined SGD 10,000 and required to retract the advertisement from all platforms.
• They also had to clarify their statement, stating that results depend on individual conditions and may require multiple sessions.

Tips for Avoidance: Fact-Checking and Legal Review Processes Before Publication

• Conduct Thorough Fact-Checking
  • Cross-check every claim with reliable sources such as clinical studies, expert opinions, or proven patient outcomes.
  • Avoid making blanket promises or statements that people cannot universally validate.
• Use Disclaimers
  • The results may vary depending on patient health, treatment adherence, or specific conditions.
  • Example: “Results may vary depending on individual health and lifestyle factors.”
• Engage Legal and Compliance Teams
  • Professionals familiar with PHMC advertising regulations should review content before publication.
  • This step ensures that language, visuals, and claims adhere to legal standards.
• Focus on Transparent Communication
  • Use phrases like “clinically proven to help reduce symptoms” rather than “guaranteed cure.”
  • Avoid superlative language unless concrete evidence supports it.
• Train Your Marketing Team
  • Conduct regular workshops on PHMC advertising guidelines for marketers, content creators, and designers.
  • Equip the team with resources, such as compliance checklists, to prevent inadvertent breaches.

PHMC Ad Guideline 4: Don’t Use Laudatory Statements

Image source: AD Health Clinic

Laudatory statements are exaggerated, overly promotional, or self-praising claims that make a medical service or provider appear superior without factual or verifiable proof. The PHMC guidelines prohibit such statements to ensure that medical advertisements remain objective, factual, and evidence-based, preventing misleading or deceptive marketing practices.

Why Are Laudatory Statements Prohibited?

• Prevents Misleading Claims
  • Statements like “The best doctor in Singapore” or “100% effective treatment” can create unrealistic patient expectations.
  • Without scientific backing, such claims may mislead consumers into believing one provider is superior to all others.
• Maintains Fair Competition: Prohibiting self-praising statements ensures that all medical institutions compete pretty based on qualifications, experience, and treatment effectiveness rather than exaggerated marketing.
• Protects Patient Trust: Healthcare decisions should be based on medical expertise and proven results, not aggressive promotional language.

Examples of Non-Compliant Laudatory Statements

Example 1: “The #1 Aesthetic Clinic in Singapore!”

• Why It’s a Violation: There is no objective way to prove this ranking unless backed by an official, recognized authority.

Example 2: “Our procedure is guaranteed to work for everyone.”

• Why It’s a Violation: Medical outcomes vary, and no treatment works 100% of the time.

Example 3: “We have the most experienced doctors in the industry.”

• Why It’s a Violation: This statement is considered self-promotional unless supported by verified credentials or certifications.

Best Practices for Compliance

• Use Factual, Verifiable Claims
  • Example: “Our clinic has successfully treated over 5,000 patients in the past 10 years.”
  • Why It Works: The statement is supported by real data.
• Cite Recognized Accreditations or Awards
• Example: “Accredited by the Singapore Medical Council (SMC) and recognized for excellence in patient care.”
• Why It Works: Refers to third-party recognition instead of self-praise.
• Use Patient Testimonials Carefully
  • Example: “Many of our patients report positive improvements, with a 90% satisfaction rate in post-treatment surveys.”
  • Why It Works: Provides measurable, verifiable data rather than vague praise.
• Stay Neutral and Informative: Instead of “We are the top-rated clinic,” say “We are a licensed and MOH-approved healthcare provider offering evidence-based treatments.”

How to Ensure Compliance

• Audit Marketing Materials: Review website content, social media posts, and ads to remove laudatory statements.
• Train Marketing Teams: Educate staff on how to create compliant yet compelling copy.
• Seek Legal and Regulatory Review: Have compliance officers vet promotional materials before publishing.
• Use Approved Medical Terminology: Stick to professional, fact-based language that aligns with PHMC guidelines.

PHMC Ad Guideline 5: Do Highlight Verified Testimonials and Reviews

Image source: Media Logic

Under the PHMC guidelines, using testimonials and reviews in medical advertising is permissible, but only if they are genuine, verifiable, and not misleading. The reasons are the following:

• Accuracy and Integrity: Testimonials reflect the experience of individual patients. Misleading or fabricated reviews can misrepresent the effectiveness of treatments or services, potentially harming patients who rely on inaccurate claims.
• Legal and Ethical Compliance: PHMC regulations explicitly prohibit using exaggerated, unverifiable, or incentivised testimonials that could unduly influence consumer decisions.
• Patient Trust: Highlighting authentic reviews fosters trust and credibility. Patients value transparency and are more likely to engage with healthcare providers who showcase genuine feedback.

Best Practices: Collecting Patient Feedback Ethically

• Request Consent for Testimonials
  • Always obtain explicit consent from patients before using their feedback in advertising materials.
  • Explain clearly how the testimonial will be used, ensuring transparency.
• Avoid Incentivization
  • Do not offer rewards or discounts in exchange for positive reviews, which may bias the feedback and violate guidelines.
  • Focus on organic testimonials from patients who voluntarily share their experiences.
• Verify Authenticity
  • Cross-check testimonials with patient records or treatment histories to ensure they accurately represent actual outcomes.
  • Avoid paraphrasing or altering the patient’s words to fit promotional goals.
• Ensure Anonymity if Requested
  • If a patient wishes to remain anonymous, use generic identifiers (e.g., “Patient A”) while respecting their privacy.
  • Anonymity should not compromise the testimonial’s authenticity or credibility.

Checklist: Steps to Ensure Testimonials Meet Compliance Standards

• Collection Phase
  • Request feedback through standardised forms that include a consent section.
  • Use direct quotes from patients to preserve authenticity.
  • Ensure the feedback reflects the actual treatment provided without embellishment.
• Verification Phase
  • Validate the accuracy of the testimonial by comparing it to patient records.
  • Avoid using reviews that make absolute claims (e.g., “100% effective”) unless supported by clinical evidence.
• Compliance Review
  • Have a legal or compliance team review the testimonial to confirm adherence to PHMC guidelines. Include disclaimers where necessary, such as:
  • “Individual results may vary based on patient-specific factors.”
• Publication Phase
  • Display testimonials in a balanced way, avoiding overemphasis on exceptionally positive outcomes.
  • Highlight a variety of experiences to provide a realistic representation of patient results.
• Monitoring and Updates
  • Regularly review published testimonials to ensure they remain accurate and relevant.
  • Remove or revise testimonials if treatments or services change significantly.

PHMC Ad Guideline 6: Don’t Make Comparisons with Competitors

Image source: DuraPro

The PHMC guidelines restrict comparative advertising in healthcare to protect the integrity of medical services and prevent misleading claims. Comparing your services to competitors, even implicitly, can lead to:

• Misinformation: Comparative statements might exaggerate differences or downplay nuances in service quality, creating false patient perceptions.
• Ethical Breaches: Healthcare is a sensitive field where trust is paramount. Negative comparisons could erode public confidence in the industry as a whole.
• Legal Issues: Singapore’s advertising regulations prohibit unsubstantiated comparative ads or disparaging competitors, which can be deemed unfair trade practices.

Fairness and accuracy are critical in healthcare advertising. Direct comparisons risk non-compliance with the law, undermining your reputation and resulting in penalties.

Examples: Scenarios Where Comparisons Have Led to Legal Action

• Aesthetic Clinic Case: A clinic in Singapore claimed that its laser skin treatment was “more effective and safer than other clinics’ treatments.” The statement lacked clinical evidence and mentioned no specific parameters of comparison.
  • Outcome: The clinic faced regulatory scrutiny and paid a fine for breaching advertising laws. The clinic had to remove the ad and issue an apology.
• Dental Clinic Incident: A dental clinic ran an online ad stating: “Our Invisalign service is 20% faster than other brands in straightening teeth.”
  • Violation: The claim was unsubstantiated and implied inferiority in competitors’ services.
  • Regulatory Action: The clinic was penalised and mandated to revise its advertisements to focus solely on its service attributes.

Workaround: How to Focus on Unique Selling Points Without Mentioning Competitors

Instead of making direct or implied comparisons, emphasise your unique strengths. Here’s how to do it effectively:

• Highlight Distinctive Features
  • Emphasise aspects like advanced technology, specialised expertise, or patient-centric care.
  • Example: “Our clinic offers cutting-edge robotic-assisted surgeries, ensuring precision and faster recovery times.”
• Showcase Achievements
  • Use awards, certifications, or accreditations to highlight your credibility.
  • Example: “Recognised as one of Singapore’s top medical centres by [Name of Authority].”
• Use Data and Testimonials
  • Present patient success stories or results supported by evidence without referencing competitors.
  • Example: “Over 90% of our patients report significant symptom relief within the first month of treatment.”
• Offer Value-Based Messaging
  • Focus on patient benefits rather than competitor shortcomings.
  • Example: “Our tailored treatment plans are designed to meet individual needs, ensuring optimal outcomes.”
• Incorporate Industry Standards
  • Align your messaging with well-recognised healthcare standards or benchmarks to implicitly convey excellence.
  • Example: “Adhering to international best practices in cardiology for over 20 years.”

PHMC Ad Guideline 7: Do Use Approved Medical Terminology

Using accurate and approved medical terminology in healthcare advertisements is critical for several reasons:

• Clarity for Patients: Patients often rely on ads to make informed decisions. Using correct terminology ensures that the information is easily understandable and avoids confusion.
• Regulatory Compliance: The PHMC guidelines emphasise that all medical terms used in advertising must be factual, scientifically accurate, and not misleading. Non-compliance can result in penalties and damage to a brand’s reputation.
• Professionalism and Credibility: Proper medical language demonstrates professionalism, reinforcing the trustworthiness of the healthcare provider.

Best Practices: Resources for Checking Approved Terminology

• Consult Medical Databases
  • PubMed: A trusted resource for peer-reviewed studies and definitions.
  • Mayo Clinic or WebMD: Useful for simplified, patient-friendly terminology.
• Refer to Regulatory Bodies
  • Singapore Medical Council (SMC): Provides ethical medical practices and terminology guidelines.
  • Ministry of Health (MOH): Offers official language guidelines for healthcare providers in Singapore.
• Use Established Medical Dictionaries
  • Merriam-Webster Medical Dictionary: For precise definitions.
  • MedlinePlus: For patient-friendly explanations aligned with approved terminology.
• Stay Updated with Industry Standards: To stay informed about evolving terminology, subscribe to medical journals or attend industry seminars.

Tips for Compliance: Involving Medical Consultants During Ad Creation

• Engage Medical Professionals Early
  • Include medical consultants in the ad creation process to review terminology and ensure accuracy.
  • Example: Before finalising an ad for a new diabetes treatment, have an endocrinologist verify the language used.
• Cross-Check with Approved References
  • Provide your consultants with references to verify medical claims and terms.
  • Ensure the language aligns with PHMC guidelines and is scientifically accurate.
• Incorporate Layman-Friendly Explanations
  • Use approved terminology but pair it with simplified explanations to ensure patients understand the message.
  • Example: “Myocardial infarction (commonly known as a heart attack) requires timely medical intervention.”
• Use Templates and Compliance Checklists
  • Develop standardised templates for ad creation that integrate approved medical language.
  • Maintain a compliance checklist that includes terminology review as a key step.
• Train Marketing Teams
  • Offer training for marketing teams on medical terminology and PHMC compliance.
  • Example: Conduct workshops with medical professionals to educate marketers on commonly used terms and their appropriate contexts.

PHMC Ad Guideline 8: Don’t Use Any Form of Promotion

Image source: VistaCreate

Under the PHMC (Private Hospitals and Medical Clinics) Act, medical institutions in Singapore cannot advertise using promotional tactics such as discounts, special offers, or package deals. This rule prevents the commercialization of healthcare services and ensures that patients make medical decisions based on needs rather than financial incentives.

Why Are Promotions Prohibited in Medical Advertising?

• Prevents Over-Commercialization of Healthcare
  • Medical services should be based on clinical needs rather than marketing-driven incentives.
  • Patients should choose treatments based on professional advice, not because of promotional offers.
• Protects Patients from Unnecessary Treatments
  • Promotions can encourage people to undergo treatments they don’t need, increasing health risks.
  • Example: A discounted botox treatment might lead patients to undergo the procedure without proper medical consultation.
• Ensures Fair and Ethical Advertising
  • Healthcare providers must compete based on service quality and medical expertise, not aggressive promotions.
  • Prevents misleading tactics such as “limited-time offers” that pressure patients into quick decisions.

Examples of Non-Compliant Promotional Activities

Example 1: “Get 20% off your first consultation!”

• Why It’s a Violation: Discounts on medical consultations could influence patients to seek unnecessary services.

Example 2: “Sign up for a health screening package and get a free treatment!”

• Why It’s a Violation: Offering free add-ons may encourage patients to undergo screenings or treatments that are not medically required.

Example 3: “Limited-time promo: Buy 5 laser treatments, get 1 free!”

• Why It’s a Violation: Package deals suggest that treatments are products rather than medical services tailored to individual needs.

Best Practices for Compliance

• Focus on Informative, Patient-Centric Advertising: Example: Instead of “50% off eye checkups,” use “Regular eye screenings help detect early signs of vision problems.”
• Highlight Service Excellence, Not Price: Example: “We provide comprehensive and patient-focused dental care, ensuring quality treatment for every individual.”
• Use Educational Content Instead of Promotions: Example: Share blog articles or expert opinions on health topics rather than running promotional campaigns.
• Provide Transparent Pricing Without Discounts: List standard service prices without promotional incentives, ensuring patients make informed decisions.

How to Ensure Compliance

1. Review Marketing Strategies: Ensure no promotional language or discount-based marketing is used.
2. Educate Your Marketing Team: Train staff to create informative content without promotional hooks.
3. Seek Legal Review: Have all advertisements checked by a compliance officer before publication.
4. Monitor Competitor Practices: Ensure your marketing remains within PHMC guidelines, even if competitors use unethical tactics.

PHMC Ad Guideline 9: Don’t Advertise Prohibited Services and Procedures

The PHMC guidelines limit advertising certain medical services or procedures to safeguard public interest, maintain ethical practices, and ensure accuracy. These restrictions often apply to services like:

• Cosmetic Enhancements: Advertisements for aesthetic procedures (e.g., botox, fillers, liposuction) are highly regulated to prevent exaggerated claims or the promotion of unrealistic beauty standards. Example: Using language that implies guaranteed outcomes or life-changing results is prohibited.
• Unproven or Experimental Treatments: Services lacking robust clinical evidence, such as alternative medicine or experimental therapies, cannot be advertised as definitive solutions.

Image source: Vista Crate

• Sensitive Procedures: Reproductive health services, such as abortion or fertility treatments, may be subject to restrictions to ensure sensitivity and compliance with local norms and laws.

Image source: The Guardian

• Weight Loss and Slimming Procedures: Claims about guaranteed weight loss or dramatic transformations through surgical or non-surgical methods often face scrutiny and are prohibited.

Examples: How Non-Compliance Has Impacted Brands in the Past

• Aesthetic Clinic’s Suspension
  • Scenario: A Singaporean aesthetic clinic ran a campaign promoting a filler treatment as “completely safe and delivering permanent results.”
  • Outcome: The ad was flagged for misleading language. The clinic faced fines and was required to halt all marketing activities until they ensured compliance.
• Weight Loss Center Incident
  • Scenario: A weight loss centre claimed that “all clients lose 10kg in two weeks guaranteed.”
  • Violation: The claim was unverifiable and exaggerated, leading to a public reprimand and financial penalties.
• Clinic Promoting Experimental Therapy
  • Scenario: A medical clinic advertised stem cell therapy as a “proven cure for degenerative diseases.”
  • Outcome: The clinic was penalised for promoting unapproved medical claims and misleading the public.

Recommendations: Staying Updated on PHMC Guidelines to Avoid Penalties

• Review Official Updates Regularly
  • For the latest updates on restricted services, visit the Ministry of Health (MOH) and Singapore Medical Council (SMC) websites.
  • Subscribe to newsletters or updates from healthcare regulatory bodies.
• Seek Legal and Compliance Expertise
  • Hire legal consultants or compliance officers specialising in healthcare advertising to review campaigns before publication.
  • Example: Conduct a compliance audit for marketing materials every quarter.
• Implement a Pre-Approval Process: Create an internal workflow where all advertisements must pass a compliance check by medical and legal professionals.
• Educate Marketing Teams
  • Train marketing teams to understand the intricacies of PHMC guidelines and prohibited services.
  • Example: Conduct workshops on avoiding exaggerated claims and identifying sensitive areas in advertising.
• Use Transparent and Factual Messaging
  • Avoid language or visuals that imply guaranteed outcomes or benefits for restricted services. Instead, focus on patient education.
  • Example: For weight loss services, use statements like “Our program supports healthy weight management through evidence-based methods.”
• Monitor Industry Trends: Keep track of enforcement actions and penalties imposed on other brands to learn from their mistakes and adjust your practices accordingly.

PHMC Guideline 10: Don’t Forget to Include Disclaimers and Transparency

Image source: Vivitrol

Disclaimers are a critical element in medical advertising. They:

• Ensure Clarity: Disclaimers give patients context about the advertised services, such as potential risks, limitations, and financial obligations.
• Support Legal Compliance: PHMC guidelines require that ads present complete and truthful information. Disclaimers help prevent misunderstandings or misinterpretation of claims.
• Mitigate Liability: Disclaimers protect healthcare providers from legal disputes related to misleading advertisements by clearly outlining terms and conditions.
• Build Trust: Transparent communication fosters credibility and confidence among potential patients.

Examples: Effective Disclaimers for Pricing, Risks, and Treatment Outcomes

• Pricing Disclaimers
  • “Prices listed are indicative and may vary depending on the complexity of the procedure and additional tests required.”
  • Why It Works: It sets realistic expectations while maintaining transparency.
• Risk Disclaimers
  • “All medical treatments carry potential risks. Please consult a licensed healthcare provider to understand if this procedure suits you.”
  • Why It Works: It educates the audience about inherent risks and encourages professional consultation.
• Outcome Disclaimers
  • “Treatment outcomes vary from patient to patient and are not guaranteed.”
  • Why It Works: It prevents exaggerated expectations and aligns with PHMC’s requirement for honest representation.
• Promotional Offers
  • “Terms and conditions apply. Discounts are valid until [specific date].”
  • Why It Works: It specifies the scope of the offer, ensuring compliance and reducing ambiguity.

Tips: How to Draft Disclaimers That Align with Legal Standards

• Follow PHMC Guidelines
  • Ensure disclaimers are factual, clear, and free of medical jargon that might confuse patients.
  • Example: Instead of “Side effects may occur,” specify “Side effects such as mild swelling or redness may occur temporarily.”
• Place Disclaimers Prominently
  • Disclaimers should be visible and easy to read. Avoid placing them in fine print or obscure locations.
  • Example: Display disclaimers directly below promotional claims or in a separate section marked “Important Information.”
• Seek Legal Review: Have a legal expert or compliance officer review all disclaimers to ensure they meet PHMC and other regulatory requirements.
• Use Standardised Templates
  • Create reusable disclaimer templates tailored to common advertising scenarios.
  • Example: A template for all pricing-related ads could include the following: “Final costs may vary based on individual assessments.”
• Update Regularly
  • Periodically review disclaimers to ensure they reflect the latest regulations and company policies.
  • Example: Update disclaimers annually or after significant regulatory changes.
• Educate Marketing Teams: Train your team to understand the importance of disclaimers and integrate them seamlessly into ad copy.
• Test for Clarity: Run disclaimers by focus groups or colleagues to ensure they are understandable to a non-medical audience.

Frequently Asked Questions

What is the purpose of the PHMC guidelines for medical advertising?

The PHMC (Private Hospitals and Medical Clinics) guidelines are designed to ensure that all medical advertisements in Singapore provide accurate, ethical, and non-misleading information. These rules protect public health, maintain professional integrity, and ensure that ads do not exploit patients’ vulnerabilities.

What happens if my advertisement does not comply with PHMC guidelines?

Non-compliance can lead to significant penalties, including fines, mandatory retractions of advertisements, and potential legal action. Repeated violations could harm a clinic’s reputation and may even result in suspension or revocation of operating licenses.

Can I include testimonials from patients in my medical advertisements?

Yes, but only if the testimonials are genuine, verifiable, and comply with PHMC guidelines. They must not make exaggerated claims, promise guaranteed results, or include comparisons with competitors. Patient consent is also mandatory before using their feedback.

Are there specific services I cannot advertise under PHMC guidelines?

Certain services, such as experimental treatments, cosmetic enhancements, and sensitive procedures like abortion or fertility services, face strict advertising restrictions. Always refer to the latest PHMC guidelines to ensure compliance.

How can I ensure my medical advertisements comply with PHMC guidelines?

To ensure compliance:

• Review the latest PHMC advertising regulations.
• Include disclaimers to clarify risks, pricing, and outcomes.
• Avoid exaggerated claims or comparisons.
• Use approved medical terminology.
• Have all advertisements reviewed by legal and medical professionals before publication.