Medical practitioners have it tougher than others when it comes to advertising their services. Whether you own a clinic or are involved in the management of a private hospital, there are stringent PHMC Digital Marketing Guidelines that regulate how you can or cannot promote your services.
Update: The Private Hospitals and Medical Clinics Act (PHMCA) has been replaced by the Healthcare Services Act (HCSA), but the guidelines are the same since 2021. More on the HCSA can be found here.
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The Singapore government first introduced the Private Hospitals And Medical Clinics (PHMC) Advertisement Regulations in 2019. It dictates how healthcare institutions and private practitioners must act when advertising their services.
It serves as the fundamental guideline to ensure the licensee of healthcare institutions registered under the Private Hospitals And Medical Clinics Acts are in compliance with the law at all times.
If you own a clinic, clinical laboratory, or manage a private hospital, you’ll want to take heed of the PHMC guidelines. You don’t want to be caught running afoul of the law by committing offences stipulated in the guidelines.
Non-compliance with the PHMC regulation can result in stiff penalties and a dent in the otherwise solid reputation of your institution.
As one of the leading digital marketing companies in Singapore, we are familiar with the PHMC digital marketing guidelines and comply with them accordingly when managing our client’s advertising campaign.
In this article, we’ll highlight the key PHMC digital marketing guidelines and how to achieve compliance.
You’ll need to be mindful of where you’re advertising because ads showing up on the wrong channel can land you in legal trouble. To simplify what’s written on the official guideline, we’ll run through a list of common advertising channels.
Advertising on traditional printed media is allowed by the regulations. You can pay for ad spaces on such publications or have your institution listed on the business directories.
It is perfectly legal to print pamphlets and brochures advertising your healthcare services. However, it is the distribution method of the materials that puts legality into question. It is against the law to send advertisement pamphlets and brochures to the recipient’s mailboxes without their consent.
The regulation on pamphlets and brochures is clearly defined. You can’t have them inserted into daily newspaper deliveries but you can make them available at your clinic or hospital. It is not against the law when patients or visitors pick up a brochure when they are at your premises.
If you’re getting the idea of blasting your customers with promotional materials, you need to drop the idea. According to the PHMC guidelines, you can’t send unsolicited messages via SMS, MMS, Whatsapp, Facebook Messenger, or any sort of messaging service.
Similar to pamphlet distribution, you’ll need written consent from the recipients before you can start doing so. Legal justification aside, it can be unprofessional to send ads to people who have not signed up for them.
With more than 5 million active users, social media is huge in Singapore. It is only natural that you want to advertise your healthcare services on a common social network. The good news is that paying for ads on social media is allowed under the PHMC guidelines.
Of all the social media networks, Youtube has the largest monthly users in Singapore. You may want to attract the viewers’ attention on the platform with catchy and engaging video ads to drive leads to your healthcare business.
You can also advertise on Facebook, where the user base is geared towards working adults. You can do this on your own but you’ll probably get the best results by engaging a Facebook ads agency in Singapore that is familiar with targeting options and strategies.
Social media are powerful advertising platforms, but you shouldn’t forget the many blogs with local followers. You can legally rent an ad space from the blog owners to promote your services. If you’re unsure how to promote your service effectively on the internet, here’s how to get started in digital marketing.
Google is the dominant search engine in Singapore and having your website found via paid ads or SEO is perfectly legal. Unlike sending ads on messengers, SEO and SEM are not considered as push technologies, and thus, they are at your disposal as lead generators.
You’ll get quicker results with paid Google ads, provided that you’re hiring an agency with credible Google ads management in Singapore. You need to get the keywords, budget and ad copy done right to get the most out of the investment.
At the same time, it’s advisable to optimise your website’s SEO if you wish to get organic search traffic with minimum cost in the long run.
What about advertising on public channels like television, billboards, light boxes, LED displays, banners and such?
Unfortunately, they are a strict no-no, according to the PHMC guidelines. None of your ads can be displayed in mediums other than those specifically green-lighted by the Ministry Of Health (MOH).
The only exception is as follows.
There isn’t any limitation imposed on how you can advertise your services within your premises. You can run video ads over private TV channels, put on large LED displays or adorn the front desk with banners.
Even if you’re given the freedom to advertise on your premises, do keep in mind that the content must still comply with existing regulations.
Throughout the years, your clinic or hospital may have won a series of prestigious awards. You would, of course, want to highlight them in the advertisements to instil trust.
However, you can only do so in a restricted manner, according to the PHMC guidelines. The guidelines specifically state that any award received by an institution can only be displayed within its own premise, website or social media page.
Therefore, it is permissible to showcase the awards in your clinic/hospital or dedicate a special gallery for that on the Facebook page. You shouldn’t, however, include a screenshot of such awards on newspaper ads.
It is also important not to confuse an award conferred to an institution with the professional qualification of a medical professional. The latter is to prove that the healthcare practitioner is qualified to serve in their position.
Besides advertising on permissible platforms, you should also be mindful of how you craft the ad content. There’s a series of do’s and don’ts outlined by the MOH for healthcare-related ads.
EEvery medical claim on the ads must be accurate. You need to include citations and proofs to substantiate claims. It’s illegal to include unproven statements just for the sake of market appeal.
You need to be sensitive to the public’s sentiments when designing the ads. The guideline prohibits usage of materials that could cause unease, fear or other negative emotions by the public. Instead, you’ll want to strike a positive tone in the ads.
The healthcare industry is very competitive in Singapore. In your bid to stand out from the crowd, you’ll need to avoid creating ads that are deemed to create unjustified expectations from the audience.
According to the PHMC guidelines, it is against the law to imply that only your institution can produce certain results. Your ads can’t contain text that runs down your competitors directly or indirectly. It’s illegal to imply in any manner that other healthcare providers are inferior to you.
Even if you’re confident in getting results for patients, you’ll want to be wary with your choice of words. Including statements like ‘Instant results’, ‘whiter teeth in 2 weeks’ and ‘transformation with only 1 session’ are prohibited. That’s because patients' experience may vary and you can’t guarantee that all will fall within the ‘expected’ results.
If you’re unsure of what is permissible, get help from an agency with proven digital marketing experience in the healthcare industry.
There’s nothing more convincing than putting up comparison pictures to prove that the treatment offered is effective. However, the PHMC guidelines prohibit such marketing manoeuvres. You’re not allowed to place any pictures depicting the results of patients who sought treatment from your institution.
Regardless of how well your clinic or hospital has been treating its patients, you’re prohibited from using laudatory terms in the ads. Terms like ‘Best’, ‘Preferred’, and ‘Unrivalled’ impress upon the audience that choosing your service is a natural decision, and, as such, are not allowed by the PHMC guidelines.
Other words and phrases you should steer clear from include:
It’s encouraging to have customers singing praises of your services. They can be a powerful form of marketing. However, there’s a restriction on how you use testimonials in your ads.
According to MOH, you’re not allowed to include testimonials in tads that are published on 3rd party platforms. For example, if you’re advertising in a newspaper, it’s prohibited to cite your patient’s words of how effective the treatment has been.
The only exception to including testimonials in ads is when you’re publishing the materials on your premise, website or social media page. Even then, the testimonials must be in their original form and remain unaltered.
Sometimes, a little financial nudge can turn an audience into a paying customer. While offering discounts is a common marketing practice, you are prohibited from doing so in a healthcare advertisement.
You can’t entice the public with discounts, promotions, free gifts, interest-free instalments or any financial benefits of choosing your service. For example, advertising a health screening package with a generous 50% discount on Facebook is against the law.
The recent joint Directive from the Ministry of Health (MOH) and the Health Sciences Authority (HSA) affects the provision of information pertaining to health products by PHMCA and HCSA Licensees (in other words, most private clinics and hospitals). The ministries have observed a growing number of feedback concerning healthcare institutions and telemedicine service providers publishing information on health products, which include therapeutic products and medical devices, on their websites or their social media platforms.
Some of the information, MOH and HSA said, is published in a manner considered as advertisements promoting the specific use of these health products. Such advertisements and publications are not allowed as they contravene the advertisement regulations within the Health Products Act (HPA).
A Health Product would be affected by this Directive, if it falls under the following categories:
Based on this Directive, the breadth of advertisement coverage extends to include the dissemination or transmission of any information that supports the sale of a health product, whether it be direct or indirect.
The Directive specifically mentions the following media:
The definitions are quite broad, and part of the Annex also mentions that reference to or featuring said products in images, or descriptions that simply imply a specific health product, can also be considered an advertisement.
Although the Directive mentions that factual or educational information pertaining to conditions, diseases and available treatments is allowed, the information must not be misleading, or create unjustified expectations of specific treatments. Once the information draws attention to a specific product, then it may be subject to these controls.
In specific wording, the Direction stated:
Taking a first-principles approach to understanding the directive, we take that the Directive is trying to remove any sort of bias or influence on patients potentially preferring one health product over another. Any potential selection of Health Product under this definition should only come after a proper clinical assessment. In the Annex, it has said as much:
The Directive has stated that all PHMCA/HCSA Licensees and TM service providers are given a grace period of up to 31 March 2023 to review your current published materials regarding health products, including product features on your websites and other digital media pages to ensure compliance with the prescribed requirements. Not doing so could lead to penalties.
The Directive is broad and leaves a lot of room to interpretation. It is subjective as to what constitutes educational content, and what may draw attention to a specific product, which can create a preference, and hence can be considered an indirect advertisement.
When we got in touch with HSA and MOH, they have also said that:
Despite our digital prowess, it can be challenging for us as an agency to definitively determine what is permissible or not when it comes to MOH new directives.
We share relevant findings or insights based on our understanding of the regulations and through our initiative to get in touch with the regulators personally. However, it is important for you to also undertake your own due diligence to avoid one party assuming greater liability than the other.
We are more than happy to conduct a thorough digital media audit for you upon request to work through your doubts.
Navigating the stringent PHMC digital marketing guidelines isn’t easy as there is a lot to consider from the perspectives of users, clinics and the government. With this explanatory guide, we hope we have made it easier for you to design your own ads and edit your current published materials.
Other useful, relevant articles that you should read before embarking on digital marketing for medical practices include:
Alternatively, reach out to digital marketing companies Singapore medical practices trust. Heroes of Digital is the leading digital marketing agency for doctors and clinics. Contact our experienced healthcare digital marketing team for more support.