Reviews and AHPRA: what clinics can and cannot do

This is the one industry where we tell people to slow down before buying anything. If you are a registered health practitioner in Australia, the rules on testimonials are stricter than most clinics realise, and a review card is a decision to take advice on rather than a quick win.

The rule

Section 133 of the National Law prohibits the use of testimonials in advertising a regulated health service. AHPRA is clear that this covers anyone advertising such a service, not just the practitioner.

A comment becomes a testimonial when it refers to clinical aspects of care. AHPRA describes those as:

• the specific symptom or reason for seeking treatment
• the specific diagnosis or treatment provided
• the specific outcome, or the skills or experience of the practitioner

Comments about customer service or communication style alone are not clinical testimonials, and can be shared.

What that means for Google reviews

Here is the part that surprises people. AHPRA states that advertisers do not have to remove, or try to remove, a review on a website or social media platform they do not control. Google is such a platform. Reviews sitting on your Google Business Profile are not, on their own, your advertising.

The restriction bites on platforms you do control. Your own website, a Facebook page you run, a booking page you operate. On those, testimonials must not appear, which for many clinics means turning the review function off.

The grey area

Asking patients for reviews is not explicitly prohibited. Using clinical testimonials in your advertising is. Between those two facts sits a genuine question: at what point does actively soliciting reviews that you know will describe outcomes start to look like using them?

We are not going to pretend we know where that line is. It is a question for AHPRA, your professional association, or your indemnity insurer, and the answer may differ between professions. What we can tell you is that it is a real question and not a theoretical one.

One thing that is clearly not allowed

Editing reviews to remove the negative ones, or filtering who gets asked, is false, misleading or deceptive conduct. That holds whether or not the reviews were clinical. It is also against Google’s policy and is the same review gating problem we describe in asking for reviews without breaking the rules.

What we would suggest instead

If you want a tap point in a clinic without wading into the testimonial question, there are uses that do not touch it at all:

• A social follow stand. Pointing at your Instagram or Facebook profile is not soliciting a testimonial. It builds the audience you use for health promotion and practice news.
• A booking link. A tag written to your online booking page, sitting at reception, removes friction from rebooking without saying anything about care.
• A practice information link. New patient forms, parking instructions, fee information, after-hours arrangements.

All of our stands and cards can be written with any destination link, not just a review page. Tell us where you want it to go and that is what we configure.

Who this does and does not apply to

The National Law covers registered health practitioners: doctors, dentists, physiotherapists, psychologists, chiropractors, optometrists, pharmacists and the other registered professions. It does not cover every business that sounds clinical. If you are unsure whether you are captured, that is itself worth checking before you advertise anything.

Sources

• AHPRA, Testimonials: understand the requirements
• AHPRA, Guidelines for advertising a regulated health service

General information, not legal or compliance advice. Advertising obligations for registered health practitioners are specific and are enforced. Check your situation with AHPRA, your professional association or your indemnity insurer before running any review campaign.