PHMC Guidelines For Private Medical Clinics

Written by Mario Didier | Head of Strategy

The Private Hospitals and Medical Clinics (PHMC) Advertisement Regulations 2019 ensures that the marketing efforts of medical practices are both ethical and responsible. The essence of these guidelines is to prevent misleading advertisements that could potentially harm the public’s health decisions. They emphasize the importance of factual accuracy, transparency, and the need to avoid overpromising results, which could lead to unrealistic expectations. The guidelines cover various aspects of digital marketing, from content creation to social media engagement, ensuring that all communications are in the best interest of the public. In this article, we will explore the key aspects of the PHMC Advertisement Regulations 2019 and provide practical insights into how medical practices can navigate these guidelines in their digital marketing strategies.

Overview of PHMC Guidelines

The PHMC Guidelines for Digital Marketing set forth by the Ministry of Health are designed to ensure that medical practices engage in digital advertising in a way that is ethical, truthful, and respectful of patient dignity and privacy. Key aspects include:

Factual Accuracy: All medical claims in advertisements must be supported by reliable evidence and presented in a clear, unambiguous manner.
Non-Offensiveness: Advertisements should respect public sensitivities, avoiding content that could be considered offensive, fear-inducing, or in poor taste.
Realistic Expectations: Marketing materials must not promise outcomes that cannot be guaranteed, thereby avoiding the creation of unjustified expectations among the public.
Prohibition of Comparative Advertising: Advertisements should not make comparisons that imply other healthcare providers are inferior.
Restrictions on Use of Images and Testimonials: The use of before-and-after images, as well as testimonials, is tightly controlled to prevent misleading representations of treatment effectiveness.
Ethical Use of Discounts and Promotions: Offers that could influence patient choices inappropriately, such as discounts or free services, are restricted.

Approved Advertisement Platforms and Restrictions

The PHMC Advertisement Regulations specify distinct guidelines regarding the platforms that medical practices can use for advertising purposes. These platforms are carefully selected to ensure that advertisements reach the public in a manner that is both ethical and respectful of the audience’s sensibility.

Approved Advertisement Platforms

Newspapers and Magazines

Catering to a broad audience with general or specific interests, offering an effective medium for healthcare advertising.

Medical Journals

Allowing for targeted advertising within the professional community, ensuring that information reaches relevant healthcare professionals.

Directories and Brochures

Providing a comprehensive listing of healthcare services, these mediums offer detailed information to those actively seeking medical services.

Leaflets and Pamphlets

Offering focused information on specific treatments or services, these are ideal for distributing detailed treatment information.

The Internet

Encompassing websites and social media platforms, the internet offers the widest reach and the ability to engage directly with the public.

Prohibited Practices and Media

Restrictions on Public Space Advertising

Prohibiting the use of television screens, billboards, light boxes, digital media boxes, LCD/LED panels, banners, and posters outside of medical practices’ premises to prevent intrusive advertising.

Internet and Social Media Advertising

Compliance Requirements

While platforms like YouTube, Facebook, Instagram, and blogs are permitted, additional compliance requirements must be met, emphasizing factual and respectful content.

In-Premises Advertising Freedom

Autonomy Within Premises

Licensees may use any advertising medium within their premises, with the responsibility to adhere to content guidelines.

Restrictions on Direct and Unsolicited Advertising

Direct and Unsolicited Communication

Prohibitions on sending advertisements through push technology or distributing free material without prior consent, safeguarding the public from unwanted advertising. These guidelines on advertisement platforms are designed to balance the benefits of digital marketing with the need to maintain ethical standards and public trust in healthcare advertising.

Specific Requirements for the Content of Advertisements

The Private Hospitals and Medical Clinics (PHMC) Advertisement Regulations mandate strict content requirements to ensure ethical, accurate, and respectful advertising in healthcare. These regulations detail what is permissible in advertisements to safeguard public trust and prevent misinformation.

Factual Accuracy and Substantiation

Advertisements must be factually accurate, capable of being substantiated, and not misleading. Evidence supporting the claims must be credible and authoritative, derived from sources like peer-reviewed journals recognized by the local medical community.

Non-Offensive and Dignified Content

Content must not be offensive, ostentatious, or in bad taste. It should uphold the honour and dignity of the medical profession, avoiding demeaning, provocative, or distasteful elements.

Realistic Expectations

Advertisements should not create unjustified expectations or imply superiority over other healthcare institutions. Claims of treatment effectiveness within a specific timeframe or session count are prohibited if they cannot be universally guaranteed.

Restrictions on Images

The use of “before and after” or “after only” images is strictly prohibited to prevent the creation of unrealistic treatment expectations.

Laudatory Statements

Use of laudatory terms in advertisements is forbidden. This includes any statements of prominence, uniqueness, or superlatives that cannot be factually substantiated.

Testimonials and Endorsements

The inclusion of testimonials or endorsements in advertisements is heavily restricted, with specific conditions under which they may be displayed.

Non-Solicitation

Advertisements must not solicit or encourage the use of healthcare services in a manner that could be deemed as encouraging unnecessary consumption of healthcare services.

Internet and Social Media Advertising Guidelines

Under the PHMC Advertisement Regulations, licensees are permitted to utilize the internet and social media platforms for advertising purposes. This reflects an understanding of the digital age’s influence on healthcare promotion and the necessity for healthcare institutions to maintain a presence where their patients are active. However, these opportunities come with responsibilities to ensure that all communications uphold the standards of ethical medical advertising.

Permitted Platforms

Licensees are allowed to advertise through:

YouTube: A platform for video content where institutions can share informational videos, facility tours, and patient education materials.
Social Media: Including Facebook and Instagram, which offer a broad reach for engaging with potential patients through posts, updates, and interactive content.
Blogs: Providing a space for more in-depth articles, healthcare tips, and discussions on medical advancements or services offered.

Compliance with Regulation 4

Regardless of the platform used, all internet and social media advertisements must adhere to Regulation 4 of the Advertisement Regulations, which mandates:

Factual accuracy in all claims and statements.
Avoidance of misleading or deceptive content.
Substantiation of all health claims with credible evidence.
Respect for patient confidentiality and privacy.

Regulation 4: Ensuring Integrity and Accuracy in Healthcare Advertising

Factual Accuracy and Substantiation

Regulation 4(1)(a) mandates advertisements to be factually accurate, substantiable, and not misleading, prohibiting exaggerations or false information. Evidence supporting claims must be credible and available upon request.

Non-Offensive and Dignified Content

Regulation 4(1)(b) requires advertisements to uphold the honor and dignity of medical professions, avoiding content that could be deemed offensive, provocative, or in poor taste.

Realistic Expectations

Regulation 4(1)(c) specifies that advertisements should not create unjustified expectations or imply superiority, prohibiting direct or indirect comparisons that suggest other healthcare institutions are inferior.

Use of Images

Regulation 4(1)(d) prohibits the use of “before and after” images that could create false expectations about treatment effectiveness.

Laudatory Statements

Regulation 4(1)(e) bans laudatory statements or superlatives not supported by factual evidence, preventing claims of superiority without substantiation.

Testimonials and Endorsements

Regulation 4(1)(f) outlines restrictions on testimonials or endorsements, ensuring they are genuine and not misleading.

Non-Solicitation

Regulation 4(1)(g) mandates that advertisements should not encourage unnecessary use of healthcare services, aiming to prevent the overconsumption of healthcare resources.

Regulation 4 is designed to ensure healthcare advertising is responsible, accurate, and maintains public trust in healthcare services.

Guidelines on Advertising Health Products and Services

The PHMC Advertisement Regulations extend specific guidelines for advertising health products and services. These rules are aimed at ensuring that such advertisements maintain the integrity and trustworthiness characteristic of the healthcare profession.

Definition and Scope

Health products include prescription medications, over-the-counter medicines, therapeutic products not registered in Singapore, and medical devices designated for professional use.
The regulations encompass advertisements across various media, including print, digital platforms, and direct communications.

Restrictions on Health Products Advertisement

Advertisements for health products must strictly adhere to the factual accuracy and non-misleading information requirements set out in Regulation 4.
There is a prohibition on direct advertising to consumers for prescription-only medicines and certain medical devices.
The guidelines specifically restrict the promotion of unregistered therapeutic products and professional-use-only medical devices to the general public.

Compliance Measures

Healthcare institutions must ensure that any promotional content related to health products does not contravene the Advertisement Regulations.
This includes avoiding claims that cannot be substantiated, ensuring that advertisements do not create unrealistic expectations, and refraining from soliciting the use of specific health products without appropriate context and disclosures.

Enforcement and Compliance

The Ministry of Health (MOH) oversees the enforcement of these guidelines, with institutions required to comply with both the letter and spirit of the regulations.
Healthcare institutions found in violation of these guidelines may face penalties, including fines and revocation of licenses.

These guidelines underscore the commitment of the healthcare sector to uphold ethical standards in advertising, ensuring that the promotion of health products and services is conducted responsibly and in the best interest of public health.

Practical Guide to PHMC-Compliant Copywriting for Medical Practices

To ensure compliance with the PHMC Advertisement Regulations while engaging in digital marketing, medical practices should adhere to several key principles in their copywriting efforts. This guide provides actionable advice to navigate these regulations effectively.

Emphasise Factual Accuracy

Ensure all claims are supported by credible evidence.
Avoid exaggerations and ensure treatments and outcomes are represented accurately.

Maintain Professional Dignity

Content should uphold the respectability of the healthcare profession.
Avoid sensationalism and ensure the tone is informative and respectful.

Avoid Unjustified Expectations

Do not promise specific results that cannot be guaranteed to every patient.
Steer clear of using absolute terms like “guaranteed results” or “permanent cure.”

Use of Images and Testimonials

Abstain from using “before and after” images that could imply guaranteed outcomes.
If using testimonials, ensure they are genuine and reflect a range of patient experiences without suggesting universal success.

Focus on Educational Content

Prioritise educational over promotional content.
Offer insights into treatments and healthcare options to aid informed decision-making.

Transparency and Disclosure

Clearly disclose any potential risks or variable outcomes associated with treatments.
Provide a balanced view of the services offered, acknowledging the complexity of healthcare.

Regular Review and Compliance Checks

Periodically review marketing materials for adherence to the latest PHMC guidelines.
Consult with legal or compliance experts to ensure all advertising content meets regulatory standards.

Compliance and Monitoring: Ensuring Adherence to Guidelines

To ensure healthcare institutions adhere to the PHMC Advertisement Regulations, a comprehensive compliance and monitoring framework is in place. This framework involves several key components designed to uphold the integrity of healthcare advertising and protect public interest.

Responsibility of Licensees

Licensees are required to ensure that all advertisements, whether digital or traditional, comply with the Advertisement Regulations. This includes accuracy, decency, and the prohibition of misleading content.
In the case of investigations by the Ministry of Health (MOH) for potential breaches, licensees must provide a timely response, typically within five working days from the receipt of a query or notice.

Monitoring and Enforcement

The MOH actively monitors healthcare advertising to identify and rectify any breaches of the regulations.
Licensees found to be in violation may be subjected to penalties, which could include fines, mandatory corrections to the advertisement, or in severe cases, suspension or revocation of the license to operate.

Rectification of Non-compliant Advertisements

Upon identification of a non-compliant advertisement, licensees are obliged to take all reasonable steps to rectify or withdraw the advertisement promptly.
The Director of Medical Services may order the alteration, withdrawal, or discontinuation of an advertisement following an inquiry into the matter.

Use of Decision Trees and Guidance

To assist healthcare institutions in determining compliance with the Advertisement Regulations, decision trees and other guidance materials are provided. These tools help licensees assess their advertisements against the regulatory requirements.

Engagement with Professional Advice

Licensees are encouraged to seek legal or professional advice to ensure their advertising practices are fully compliant with the regulations.
Regular training and familiarization with the Advertisement Regulations are recommended for all healthcare providers involved in advertising and marketing activities.

Our Thoughts

If your healthcare institution is looking to get ahead in this dynamic environment, partnering with a high-performing healthcare marketing agency in Singapore offers a strategic advantage. A specialized agency will be able to leverage existing data and expertise while navigating the complexities of PHMC regulations and maintaining compliance. Speak to us to learn more!