Advertising and digital marketing play a key role in shaping and growing businesses and their brands, but there are strict regulations to follow when it comes to healthcare. Every advertising campaign run by a healthcare licensee had to comply with the Private Hospitals and Medical Clinic (PHMC) guidelines, which were introduced in 2019 by the Ministry of Health (MOH). These regulations were established as a guide for healthcare providers to promote their services responsibly. Any claims about their services had to be backed by evidence and not likely to mislead or exaggerate. These include superlative claims, endorsements, testimonials, before-and-after photos, and comparisons with another licensee’s services, or to deprecate another licensee’s services. Information presented must not be false, exaggerated, misleading or deceptive, and must be factually accurate and capable of being substantiated with clinical or scientific evidence.
The Healthcare Services Act (HCSA) 2020 replaced the older PHMC framework (Private Hospitals and Medical Clinics Act) primarily because the rise of digital and influencer marketing rendered the previous regulations outdated. While the HCSA introduces new rules for most licensed healthcare services, the PHMC regulations still apply in certain transitional cases and for specific, usually older, types of services.
What are HCSA Regulations?
The Healthcare Services Act (HCSA) is a regulatory framework that oversees healthcare licensing and advertising in Singapore. All forms of promotional content, such as websites, social media, or print media, must comply with these regulations to:
- Prevent unrealistic expectations about medical treatments.
- Prevent the use of unethical marketing practices that could mislead the public.
- Certify all medical claims are backed by evidence.
- Promote transparency and factual accuracy to help patients make informed decisions.
Advertisements must not promote or encourage unnecessary healthcare services, make deprecatory comparisons against other healthcare providers, give laudatory statements about their treatments, products and services, or exaggerate results of such products, treatments, and services to the public.
The HCSA regulates advertising for all licensable healthcare services, including:
- Private hospitals and medical clinics.
- Dental clinics and radiological labs.
- Allied health professionals (HCSA enables the regulation of services offered by Allied Health, Nursing, and TCM practitioners).
- Telemedicine providers (A main reason for HCSA’s creation was to regulate new models like telemedicine as part of Outpatient Medical Services and others).
- Clinical labs and nursing homes.
HCSA Guidelines vs PHMC Guidelines – Key Differences
The Healthcare Services Act (HCSA) 2020 was promulgated (passed by Parliament) in Singapore in January 2020, and implemented in phases from 2022-2023. The HCSA was enacted in 2020 to replace the PHMC Act. It takes a more flexible approach to regulate healthcare services beyond physical premises. This allows for new care models and services to be included, and provides regulatory clarity to healthcare providers to support patient care and continuity.
The differences introduced in the 2020 HCSA Guidelines included the following changes:
- Covers all licensed healthcare services (including allied health and telemedicine).
- Provides detailed guidelines on permissible claims with tighter enforcement.
- Includes digital marketing platforms and influencer marketing.
Dos and Don’ts Under the HCSA
Healthcare providers must ensure all advertising criteria are followed under the HCSA guidelines. Here are some key points to look out for:
Dos
- All advertisements must be factual, accurate, and supported by clinical evidence.
- Be transparent when communicating with patients and when stating fees.
- Advertisements must only show the services healthcare providers are licensed to provide.
- Reviews or testimonials by patients should only be used if they are factual, verifiable, and do not exaggerate outcomes.
- If working with an influencer, they must act under the service provider’s authorisation, and content must comply with HCSA regulations.
Don’ts
- Do not use “before and after” to imply guaranteed outcomes or exaggerate the likely results of a treatment.
- Avoid superlative or self-praising phrases like “Best doctor” or “guaranteed results”.
- Avoid offering promotions or discounts that could induce patients to seek treatment.
Unknowingly breaking the HCSA guidelines can be a serious problem for your business. Failure to adhere to these rules can lead to monetary fines or licence suspension, which can damage your reputation as a healthcare provider and your credibility with patients, regulators, and the wider medical community.
How Our Digital Marketing Agency Keeps Your Healthcare Advertising Compliant
Staying up to date with the HCSA guidelines and running effective marketing campaigns at the same time is tough. Cleverly takes this weight off your shoulders to make sure every campaign is both ethical and impactful.
At Cleverly, we create strategies that are in full compliance with the HCSA guidelines in the following ways:
- Ensuring all medical-related content and advertising campaigns meet the standard HCSA requirements.
- Crafting SEO-friendly blog articles that educate patients.
- Develop marketing strategies that build trust without being restrictive.
- Monitor campaigns and provide ongoing support across digital platforms to prevent compliance and non-compliance issues.
Advertising in Singapore’s healthcare industry is highly regulated, and healthcare providers must follow these guidelines for the sake of public health and patient safety. If you are unsure of where your healthcare advertising stands, get in touch and let us assist you.
FAQs
Are healthcare providers allowed to compare with other healthcare providers, even if they are not named?
No, healthcare providers are not allowed to compare their services with other healthcare providers.
Are healthcare providers allowed to advertise services on online shopping platforms?
Yes, but they must be mindful of the HCSA requirements for the content.
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