The business of medicine and health comes with heavy regulations. In this day and age of technology, businesses have constantly consulted digital marketing and advertising agencies in promoting their products, improving their brand recollection and driving profits. But for those licensed under the Private Hospitals and Medical Clinics Act, these advertisements come with regulations that must be followed to ensure that their clients are accurately informed of their services.
The Private Hospitals and Medical Clinics (PHMC) Advertisement Regulations became effective in 2019 by the Singapore Government. Since then, the PHMC advertising regulation ensures that licensed healthcare institutions under the PHMC Act comply with the law.
All licensed institutions under the PHMC Act should familiarise themselves with the PHMC advertising regulation otherwise they would be held liable under the law. These regulations provide for the different platforms and channels to be used in advertising PHMC services and treatments as well as information these ads must contain.
The PHMC advertising regulation aims to provide clarity in the advertisement of services by healthcare institutions, giving the public a better understanding of their services and helping them arrive at informed decisions. Its framework balances the creative advertising ways in social media with the need to not create unrealistic expectations.
If you have trouble understanding the PHMC guideline, we’ve made it easy for you in this article to help you navigate through the law.
There are several limitations on how to advertise based on the location and channel, failure to comply with this would lead to legal repercussions.
Here’s a simplified list based on the guideline on which platforms and channels you’re allowed to use to advertise:
Private hospitals and medical clinics are allowed to use traditional printed media in advertising services. However, you have to make sure that any advertisement not displayed on your premises must only appear in newspapers, directories, medical journals, magazines, brochures, leaflets and pamphlets.
You have the choice to have your institution listed in business directories or you can pay for ad spaces on such publications. The PHMC guideline, however, disallows you to send advertisement pamphlets for free to potential clients without their written consent or inserting pamphlets and brochures in daily newspaper deliveries.
Advertisement through technology is not necessarily disallowed in the PHMC guidelines.
The usage of SMS, MMS, Whatsapp and Facebook Messenger to advertise services through unsolicited messages is disallowed without first obtaining the written consent of the recipient since the PHMC guidelines strictly prohibit push technology in advertising.
With nearly all Singaporeans subscribing to social media, the need to advertise healthcare services through this platform is only natural. Fear not, however, as the PHMC guideline allows usage of social media networks provided that the content follows existing advertising regulations.
Different social media platforms call for different target audiences. You can benefit from the heavy user traffic Youtube gains from Singapore and advertise through creative and engaging video ads for your institution and its services.
You might also consider Facebook and attract a healthy base of users from working adults, or move to Instagram to advertise to the young adult demographic. If several blogs caught your eye and are serving your target clientele, you might also consider getting an ad space from them to advertise your services.
Good news: SEO and SEM are not considered push technologies under the PHMC guideline and it's perfectly legal to use them as your lead generators. With Google as the dominant search engine in Singapore, you can optimise your website’s SEO or pay ads to gain search traffic to your website.
If you’re looking forward to advertising through other public channels such as television, billboards, LED displays, banners, light boxes, and posters then you might want to bring that idea to a stop. The PHMC guideline only allows the listed eight media platforms when advertising outside your premises, and the use of the wrong channel might land you in serious legal trouble.
The good news is that it is subject to the exception, provided that the advertisement is within your physical premises
The PHMC guidelines allow using any medium when you’re advertising within your premise. You are allowed to run ads on private TV channels and LED displays and place numerous posters and banners around. However, the content must still ensure compliance with existing advertising regulations.
It is not just the platforms and channels that you must comply with. The PHMC guidelines also have specific requirements for the content of your ads. We’ve provided a list of the requirements below that you must use in creating your ad content.
Every information contained in your ad must be factually accurate. They must be substantiated and cited with credible and authoritative sources from journals or other literature. Using uncorroborated statements to appeal to clients is not only illegal but also damages your image and reputation.
Your ad must not contain any word, image or information that’s offensive, demeaning or that would undermine the medical, dental or nursing profession. Exhibit sensitivity and use a positive tone in the creation of your ads that would provide positive emotions to the large audience seeing them.
While it is important to stay above your competitors, don’t create unjustified expectations of the services provided and treatment offered by your audience. The PHMC guidelines disallow information that would imply that your treatments and services produce certain greater quality and instant results compared to others.
While confidence is needed in assuring your patients of better outcomes, you have to avoid using words that would otherwise promise guaranteed results.
While there’s no better proof of the effectiveness and quality of your services than placing comparative and result pictures, the PHMC guidelines forbid using these in advertising. These pictures may be used only during consultations with proper context from your institution’s professionals provided with explanations and clarifications of expected outcomes of the treatment or service. Otherwise, even with disclaims, these pictures are not allowed as advertisements.
Your healthcare institution might have received several awards or might be best known for specific fields, but you’re still prohibited to use laudatory terms and statements in your advertisements. Some words and statements that the PHMC guidelines have prohibited are ‘Better’, ‘Excellent’, and ‘Leading’ to name a few. Other common words disallowed by the guidelines are ‘State-of-the-art’, ‘Premier’, ‘Renowned’, and ‘Number 1/One’.
There’s no better advertisement than the praises and endorsements of former clients about your treatments and services. After all, one of the most powerful tools of marketing is word-of-mouth. If you’re advertising through third-party platforms, you’re not allowed to use testimonials or the statements of your patients to testify about your treatments and services.
The only exception to this is that may use your patients’ testimonials when it’s published within your physical premises, through your website or your social media. Patients may also provide their direct feedback on your services through their own social media accounts, but you’re not allowed to coerce them into doing so for a valuable consideration.
Discounts remain as one of the common marketing practices as it entices anyone to buy and support brands as long as they get to save a portion of their buck. While it remains a viable marketing tactic, you’re not allowed to use promotions, discounts or alternative payment schemes to entice clients into choosing your services.
Hyperlinks are used in digital marketing to mainly provide further context or to further marketize content with other related content. However, the use of hyperlinks in the healthcare business is much more regulated. If you’re planning to use hyperlinks in your website to direct it to another website, there are rules you must take into account:
Once you become aware of any hyperlink that contravenes these rules, you are required to remove it immediately.
The display of awards and distinctions is regulated by the PHMC guideline as well. It is specified that any award you receive can only be displayed on your physical premises, website and social media page.
You’re not allowed to use screenshots or photos of your awards to be used in a newspaper ad. The display, publication or conveyance of any award within your physical premises or through your website and social media must still be in compliance with the PHMC guideline and must not be exaggerated, false, misleading or deceptive.
You and your employees may be interviewed at the request of any print and broadcast media organisation with the consent of the interviewee. The interviewee must ensure that any information about the institution they provide during the interview must comply with the PHMC guidelines' specific requirement for content as discussed above. They’re expected to provide factually accurate information applied to professional ethical codes and ethical guidelines.
If there’s filming on your premises, you or your employee involved must not solicit any person to participate in the filming. You must also make sure that only the name of your institution is shown in the credits to show acknowledgement.
You are allowed to advertise events organised and hosted by you. According to the PHMC guidelines, you just have to make sure that the advertisement of these events contains information that is factual and the following:
The materials distributed during the talks, workshops or symposiums must contain factually accurate information that follows the prescribed requirements discussed above and does not promote your services.
Any gift or benefit a patient may receive based on the service they purchased from your institution is prohibited to be advertised, except for programmes related to the Government of the Health Promotion Board, including its public schemes. Should your institution participate in the national schemes, ensure that the templates you use when advertising your services are provided by the relevant public authorities. These ad collaterals must comply with the requirements discussed above.
Contributing to a good cause is always a welcome initiative for everyone. You might have done donations and contributions to several recipients which you’re excited to advertise. In terms of contributions for good causes, the only information the recipient can publicly state as an acknowledgement of your contribution is the name of your institution.
In terms of CSR programmes, there are conditions that you must satisfy:
Any advertisement of your services together with any activity, event or programme of any person must follow the PHMC guidelines discussed above. As an example, when there’s an advertisement of a preferential rate for members of a club, society or company, it should only contain the net price without comparison to the price offered to non-members.
You are allowed to engage the professional help of a digital marketing company in Singapore to publicise information, provided that it adheres to the PHMC guidelines.
If you’re looking forward to advertising outside of Singapore, then the PHMC guidelines no longer apply. Nonetheless, you must prove that the ad is meant only for an overseas audience and such an ad is not accessible to the general public in Singapore, in the normal course of events.
If the advertisement is accessible to the general public in Singapore in the normal course of events, such as the internet or social media, then it would have to follow the PHMC guidelines. When advertising overseas, you must comply with applicable laws and regulations (including the country of publication) about the advertisements.
The healthcare industry is not an easy field to navigate. Its business character necessarily involves different regulations that exist to protect not only the general public but also the business you’re planning to flourish.
While the regulations for private hospitals, medical clinics and clinical laboratory might be a little challenging to understand, following the guidelines will ensure good brand recollection for potential clients and customers who prioritise truth in their choices. You can access the PHMC regulation here for more information.
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