Protecting Your Reputation Without Violating FTC Guidelines

The FTC’s recent rule on fake and manipulated reviews went into effect in October 2024. Healthcare providers would be wise to align their review generation practices with regulatory requirements. Violations can lead to steep fines exceeding $50,000 per infraction, making compliance more critical than ever.

For example, in 2023, a Manhattan doctor was fined $100,000 for manipulating online reviews, highlighting the significant risks involved. AND this was BEFORE the FTC wrote the new rules and penalties.

Read more about this case in the NY Attorney General’s press release.

In 2024, a Seattle-area medical provider agreed to a $5 million settlement after the Washington Attorney General found the clinic used gag clauses and fake reviews to silence patients — one of the largest review enforcement actions to date.

Read more about this case in the WA Attorney General’s press release.

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FTC Compliance Requirements for Review Generation

We’ve compiled some useful guidelines to help healthcare providers avoid violating the: FTC’s 2024 Fake & Manipulated Reviews rule

Genuine Reviews Only – All reviews must be from real patients, residents, family members, or visitors who have firsthand experience with the care provided.
No Incentives for Positive Reviews – Offering discounts, gifts, or other incentives in exchange for positive reviews is prohibited.
No Review Suppression or Filtering – You cannot selectively ask only satisfied patients for reviews while ignoring or discouraging those who may provide negative feedback.
Transparency in Solicitation – If a business requests reviews, it must do so in a neutral manner without influencing the content or star rating.
No Fake or Insider Reviews – Employees, owners, or affiliated individuals (i.e. their family members) cannot post reviews about their own facilities without clear disclosure.
No Review Manipulation – Editing, removing, or hiding negative reviews while displaying only positive ones is considered deceptive.

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Common Ways Healthcare Providers Violate FTC Guidelines

Even with good intentions, some facilities may unknowingly engage in practices that put them at risk of enforcement actions. Here are some examples of violations:

Only Asking Satisfied Residents and Families for Reviews
If your facility only requests reviews from those who have had positive experiences while avoiding outreach to those with complaints, this is considered gating and/or review suppression.
Offering Gift Cards or Discounts for Positive Reviews
A common but risky practice is providing incentives in exchange for a 5-star review. While rewarding participation in a survey is permissible, tying incentives to positive feedback is not.
Using Staff or Corporate Accounts to Post Reviews
Some providers have asked employees or corporate staff to leave reviews posing as patients or family members. This is a direct violation of the rule and has resulted in enforcement actions, such as a 2023 case where a Manhattan doctor was fined $100,000 for manipulating reviews. If you are asking employees (or family members of employees) to post a review, it must be accompanied by proper disclosure of relationship to the organization to avoid being considered deceptive or manipulated.
Editing or Removing Negative Reviews
If a facility manually removes, hides, or edits negative feedback on third-party sites like Google or Facebook, it may be engaging in deceptive practices and review suppression that violate FTC regulations.

Conclusion

Protecting Your Organization from Risk

Healthcare providers should take proactive steps to ensure compliance, including:

Implementing a transparent, neutral review request process.
Avoiding incentives tied to review outcomes.
Training staff on FTC regulations regarding reviews.
Using third-party platforms like REVIEWLocal.org that align with compliance guidelines and allow real-time feedback without manipulation.

By following these best practices, healthcare providers can build trust with families and referral partners while avoiding costly penalties. If you’re unsure whether your current review generation process is compliant, now is the time to audit your approach and make necessary adjustments.
For more information on compliance and best practices, schedule a consultation with our team today!

Disclaimer: The information provided in this article is for general informational purposes only and reflects our opinions on best practices. This is not legal advice. We strongly encourage healthcare providers to consult with a qualified attorney to understand how FTC regulations apply to their specific situation.

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