It is an undeniable fact that advertising and digital marketing are key elements when it comes to business proliferation and driving conversions. However, when it comes to advertising their services, medical practitioners face more challenges than others. The PHMC Advertisement Regulation Guideline governs how healthcare institutes (HCIs) can or cannot market their services, whether you own a clinic or manage a private hospital. Adhering to these guidelines is imperative as it ensures that you are compliant and following the regulations.
Definition of PHMC Advertisement Regulations
PHMC stands for Private Hospitals and Medical Clinics. The PHMC Advertisement Regulations Guideline was introduced by the Singapore government in 2019. It sets precedence on how HCIs and private practitioners should advertise their services, which includes digital marketing. A licensee of a hospital or clinic registered under the Private Hospitals and Medical Clinics Act is expected to follow this guideline at all times. Failure to comply with these regulations may result in serious consequences including penalties that may tarnish the reputation of your institution. Private hospitals, clinics, and clinical labs should take note of the PHMC Advertisement Regulations Guideline in order not to run afoul of the law by committing offences stipulated in the guidelines.
Objectives of PHMC Advertisement Regulations
No doubt, rules and regulations can result in much confusion, especially when there are a lot of them. Before the PHMC Advertisement Regulations Guideline, there was the PHMC Publicity Regulations, which was released in 2004. However, a veritable explosion of medical advertisements has occurred since the advent of the Internet and new media channels. This includes targeted Google ads, blogs and even Facebook marketing for clinics. Since the medical landscape has transformed and evolved vastly, the PHMC Advertisement Regulations Guideline was created with this in mind, setting the standard for medical advertising and digital marketing in Singapore.
Compared to the PHMC Publicity Regulations, the PHMC Advertising Regulations Guideline serves to provide greater clarity. This is achieved by updating regulatory frameworks to accommodate the emergence of creative and innovative ways to market healthcare services, such as through social media marketing in Singapore. The PHMC Advertisement Regulations Guideline apply to advertisements, which promote the services of healthcare institutions (HCIs), rather than their publicity. The main difference between the two is that ‘publicity’ does not promote the use of HCI services but rather, offers information about them.
Primarily, according to the PHMC Advertisement Regulations Guideline, HCI advertisements cannot create unrealistic expectations about the services provided, nor should they induce unnecessary consumption of healthcare services. They should only inform the public about their services, allowing them to have a more in-depth understanding, and, therefore, be able to make their own informed decision with regards to their healthcare choices.
The PHMC Advertisement Regulations Guideline contains a myriad of rules that HCIs are required to comply with. This may be difficult to digest with the amount of topics and mandates involved. As a digital marketing agency in Singapore with a range of clients including those in the healthcare industry, we take pride in understanding every aspect of the PHMC Advertising Regulations Guideline. Our marketing and advertising efforts are in compliance with the guideline, giving our clients greater assurance that their brand is in good hands. Therefore, in the next portion of this article, we will break down and highlight the different regulations to help you better achieve compliance.
Advertising on the wrong channel could put you in legal trouble, so be careful where you place your advertisements. Licensed HCIs must ensure that advertisements revolving around their services, which are not displayed on their premises, appear exclusively in newspapers, directories, medical journals, magazines, brochures, leaflets, pamphlets and the Internet.
The PHMC Advertisement Regulations Guideline permits advertising on traditional printed media. Advertisements in such publications can be purchased, or your institution can be listed on business directories. Marketing your healthcare services through brochures and pamphlets is perfectly legal as well. However, do take note when it comes to distributing these materials. Without the recipient’s consent, it is illegal to send advertisement pamphlets and brochures to their mailboxes. Though brochures and pamphlets cannot be inserted into daily newspaper deliveries, you can still make them available at your clinic or hospital. Just remember to insert the date of the publication.
Apart from traditional media, new media is now the go-to solution for digital marketing including social media marketing. For instance, social media has 4.5 million active users in Singapore. This makes it ideal for HCIs to want to advertise their services on such platforms for greater outreach and visibility. Fortunately, paying for ads on social media is permitted! Another popular digital marketing platform is YouTube. Today, YouTube has over 2 billion active users. Creating engaging video ads that grab viewers’ attention on YouTube can help drive prospects to your healthcare business. In this sense, a social media marketing company in Singapore will be of great help.
While social media gains wider outreach, so do search engines. Having your website found through paid advertisements or search engine optimisation (SEO) is legal and since Google is the dominant search engine in Singapore, it should be leveraged for more effective digital marketing. Search Engine Marketing (SEM) and SEO do not qualify as push technologies, thus, they can be used as lead generators. For example, blogs are a great way to boost SEO. Beyond creating blogs for your own website, you can also do guest postings on third party websites. If you are unfamiliar with SEO practices, engaging an SEO agency in Singapore comes in handy. They can guide you through the different SEO elements such as keywords and ad copies to maximise your investment.
While the above methods of advertising are permitted, keep in mind that advertising on public channels including television, billboards, light boxes, digital media boxes, LCD/LED panels, banners and posters are not allowed. Unsolicited messages sent via messaging services like SMS, MMS, WhatsApp, Facebook Messenger are not permissible as well. However, any advertisement that is displayed within the premises of the healthcare institution may appear in any form or medium.
Display of Accreditation, Certificates or Awards
Accreditations, certificates and awards all reflect credibility and prestige. Should your HCI have attained these, it is only natural for you to want to showcase them to cultivate greater trust among potential patients. It is important to be mindful of the restrictions entailed when displaying such accreditations. An institution is only allowed to display any accreditation, certificate or award it receives in its own premise, website, or social media page, as stated in the guidelines. They should also not be exaggerated, false, misleading or deceptive. Do take note that accreditations, certificates and awards are different from medical professionals’ qualifications. Qualifications from medical professionals simply substantiates that they are well-qualified and positioned to perform their responsibilities in the HCI.
Specific Requirements for the Content of Advertisements
A big part of digital marketing is the content that is used in advertisements. No advertisements would perform well without content. With regards to this, there are 7 main regulations that licensees of HCI’s should be aware of as listed below.
1. Advertisements must be factually accurate and capable of being substantiated
Advertisements must contain accurate and verifiable information at the point when they are published, disseminated, and/or communicated. This includes information such as claims, assertions, statements and more. There must always be sufficient evidence to support and validate your content. Credible and authoritative sources such as PubMed’s peer-reviewed journals and articles or other research that is recognised and accepted by the local medical community all counts as evidence. You are also required to cite these resources in your advertisements and provide them to the Ministry of Health (MOH) upon request. Absence of such evidence translates to failure in complying with this rule.
2. Advertisements must not be offensive, ostentatious or in bad taste
Any words, statements, images, or other information contained in advertisements must not be demeaning, provocative, distasteful, indecent, or undermine the honour of the medical, dental, or nursing professions. Afterall, it is imperative to remain conscious to the public, especially for a sensitive topic such as health. For instance, including nudity in your digital marketing advertisement would mean that you are not in compliance with this particular rule. It is best to incorporate a positive tone in your advertisements.
3. Advertisements must not create unjustified expectations
One of the biggest challenges of owning your own businesses lies in setting yourself apart from the competition who may be offering similar services. In an attempt to stand out, some companies might unknowingly create unjustified expectations in their advertisements. This is strictly prohibited. For example, using terms such as ‘instant results’, ‘immediate’ or anything encapsulating generally short treatments constitutes unjustified expectations. This is because each patient is different with varying conditions. While one patient might see results in a day, another might take longer depending on the individual and condition. Not all patients can achieve the same results in the same time period. In addition, images and videos that compare treatment results and quality of one HCI to another are not allowed as well. You cannot claim that your services will produce better outcomes than that of another HCI.
4. Advertisements must not contain ‘before and after’ or ‘after’ only pictures.
In digital marketing, comparing pictures is a powerful way to prove that the treatment offered is effective. Unfortunately, this is not allowed according to the PHMC Advertising Regulations Guideline. Photographs, pictures, videos or films that feature ‘before and after’ or ‘after’ only content is not permitted even if there are disclaimers involved. The only time you can showcase such content is when a patient consults you in your HCI premises. Even then, proper context, clarification and explanation of the treatment and services must be provided by the medical professional. In this way, patients can make more well-informed decisions on their own.
5. Advertisements must not contain laudatory statements
Subjective praises, commendations and compliments are all considered to be laudatory statements and hence, should not be used. To ensure that the statements in your advertisements are factually accurate, below is a list of terms you should avoid using.
6. Advertisements must not contain testimonials or endorsements
From digital marketing to traditional media marketing, the platforms/area where patients, caregivers and members of the public can provide direct feedback through testimonials and/or endorsements regarding a HCI’s services are as follows:
- HCI’s website or social media
- Patients’, caregivers’ and members of the public’s websites or social media
Patients, caregivers, and members of the public should not be coerced or offered valuable consideration in exchange for testimonials and/or endorsements by HCI licensees.
7. Advertisements must not solicit or encourage the use of the HCI’s services
Advertisements cannot contain any information which encourages or solicits a consumer to use an HCI’s services. ‘Before and after’ content, promising quick, effective results and leveraging on cheaper prices such as ‘promotions’, ‘packages’ and ‘discounts’ are examples of soliciting and encouraging the HCI’s services. When it comes to payment plans, patients can be informed at the HCI’s payment counter.
In digital marketing, there is always the concern of hyperlinks and the hyperlink rules are even more stringent for HCI licensees. If you are using a hyperlink in your website that links to an external website, below are some factors to take note of. The external website should not:
- Contain false, misleading, inaccurate, exaggerated, or deceptive information.
- Be in bad taste, offensive, or undermine the honour and dignity of the professions of dentistry, medicine, or nursing.
- Imply or create unjustifiable expectations of their services and compare their services to other HCIs, insinuating that they can do what other HCIs cannot.
- Contain photos, images or videos of ‘before and after’ or ‘after’ only content.
- Contain laudatory statements, testimonials and endorsements (with the exception of number 6 above).
- Solicit and promote the use of the HCI’s services.
In the course of planning digital marketing activities on your website, should you be aware of a hyperlink, leading to an external website that includes any of the above, you are required to remove the hyperlink immediately.
Particular Factual Scenarios
These include interviews, filming on HCI premises and public workshops, seminars or symposiums. For interviews, you or your employee may be interviewed at the request of any print or broadcast media organisation. However, during the interview, do ensure that what you or your employee is stating complies with the regulations mentioned under the segment ‘Specific Requirements for the content of Advertisement’ above.
With regards to filming, you or your employee involved must not solicit anyone to participate in any filming within the premises of the HCI. If the film is shot on the premises of a HCI, do ensure that only the name of your institution appears in the film’s closing credits as a sign of acknowledgment.
When it comes to public workshops, seminars or symposiums, it is permissible for you to advertise workshops, seminars, symposiums or talks hosted by your HCIs. Just ensure that the information on the advertisement is limited to the following only:
- Title and synopsis
- Information on the speakers i.e. names, registered professional qualification(s), professional title(s) reflecting the register(s) in which the speakers are registered (if any), qualification(s) accepted and recognised for display by the relevant professional bodies (if any) and the name(s) of the place(s) of practice
- Details of the programme and timing
- Venue and contact information for the event
- Fees and charges that may apply, the period for which these fees and charges are applicable and the accepted mode of payment
- Name(s) and details of the organiser(s) and / or sponsor(s)
At the talk, materials distributed must comply with the rules mentioned under the segment ‘Specific Requirements for the Content of Advertisements’ and should not promote the services of your HCI.
Participation in Public Schemes
Where a gift or benefit is involved when a patient engages your HCI, it should not be advertised either through digital marketing or traditional media marketing. The only exception is if the programme is related to the Government of the Health Promotion Board. This includes public schemes by them. Should your HCI participate in national schemes, do ensure that templates used are provided by the relevant public authorities when advertising their services under the schemes. Most importantly, as per usual, all advertising collaterals must comply with the ‘Specific Requirements for the Content of Advertisements’ portion mentioned above.
Contributions to Good Causes and Participation in Corporate Social Responsibility (CSR) Initiatives
Over the years, your HCI may have made several contributions in the form of donations and sponsorships, which you might want the public to know about, building greater positive associations to your brands. However, do be aware that the only information the recipient can provide as public acknowledgement of your contribution is the name of your HCI. When advertising CSR initiatives or programmes, you must explain that the advertisement is related to the CSR programme.
Advertising in Conjunction with any Person
Any time an advertisement is placed in conjunction with an activity, event or programme of any person, it must follow the mandates as stated in the section ‘Specific Requirements for the Content of Advertisements’ above. If an advertisement describes a preferential rate to members of a club, society, or company, the price should not be compared to that offered to non-members.
Often HCIs may engage the help of a digital marketing agency to help them through their advertising and marketing campaigns. While it is important for the agency to be aware of these guidelines and ensure compliance while creating advertisements for the campaign, it is ultimately the responsibility of the HCI licensee to see to it that all works generated by the agency are compliant as well.
Advertisements Outside Singapore
So far, we have covered all the rules and regulations of both physical and digital marketing HCIs must remain compliant with in Singapore. With that being said, what if advertisements are marketed outside of Singapore? In this case, the above regulations do not apply. Nevertheless, you must be able to prove that the advertisement is meant only for an overseas audience and is not accessible to the general public in Singapore, in the normal course of events.
Should your ads be published through a mass medium and is accessible to the general public in Singapore in the normal course of events, then the above regulations will apply. Licensed entities should ensure they comply with all applicable laws and regulations (including those of the country of publication) when advertising overseas.
At the end of the day, to establish compliance with the PHMC Advertisement Regulations Guideline, take extra precaution into ensuring that the style and content of your HCI advertisement meet all applicable requirements. For greater clarity on whether or not your ads are compliant, below is a decision tree to help you determine so. Before rolling out any advertising or digital marketing campaigns in Singapore, do leverage this decision tree to assess, evaluate and familiarise yourself with the PHMC Advertising Regulations Guideline.
We understand that navigating the rules of the PHMC Advertising Regulation Guideline can be a challenging and daunting process. Ultimately, it is worthwhile to engage the services of a digital marketing agency in Singapore such as ourselves, who are familiar with these regulations and will help you maintain compliance. Beyond compliance, we also pride ourselves on effective SEO marketing in Singapore. Guiding you through the different SEO practices and social media marketing is our forte.
OOm is an award winning digital marketing agency in Singapore. We provide a range of digital marketing services including SEO marketing, FaceBook marketing, social media marketing and more! Contact us today for more information!