Healthcare Compliance in Digital Marketing: MOH Guidelines for Singapore Clinics

Healthcare providers in Singapore must navigate strict regulatory frameworks when promoting their services digitally. The primary guidelines governing this space are the Healthcare Services Act (HCSA) regulations, which replaced the earlier Private Hospitals and Medical Clinics (PHMC) Advertisement Regulations 2019.

Regulatory Framework

The HCSA guidelines apply to all licensed healthcare providers, including private hospitals, medical and dental clinics, radiological and clinical laboratories, allied health professionals, and telehealth services. These regulations were designed to ensure transparent, ethical advertising while protecting patient safety and preventing misleading marketing practices.

Permitted Digital Marketing Channels

Healthcare providers have several approved options for digital marketing:

Search Engine Marketing and SEO are fully acceptable because they rely on pull-based strategies where patients actively search for services. Paid social media advertising is also permitted on platforms such as Facebook, Instagram, and TikTok, provided the messaging complies with content guidelines. Additionally, influencer collaborations are allowed, though influencers must act under the healthcare provider's authorisation and ensure all content meets HCSA requirements.

Approved traditional media for advertising includes newspapers, directories, medical journals, magazines, brochures, leaflets, pamphlets, and the Internet.

Key Content Requirements

All advertisements must adhere to strict content standards:

• Factual accuracy: All advertisements must be factual, accurate, and supported by clinical evidence.
• Transparency: Healthcare providers must be transparent when communicating with patients and stating fees.
• Licensed services only: Advertisements must only show services the provider is licensed to provide.
• No misleading claims: Superlative or self-praising phrases such as "Best doctor" or "guaranteed results" are prohibited.

Prohibited Advertising Practices

Several practices are explicitly forbidden under HCSA guidelines:

Before-and-after content is not permitted if it implies guaranteed outcomes or exaggerates treatment results. Patient testimonials and endorsements cannot be used in advertisements, even if authentic. Promotional pricing is restricted—healthcare providers cannot offer promotions or discounts that could induce patients to seek treatment. Additionally, souvenirs, promotional coupons, and vouchers are not allowed.

Influencer and Third-Party Marketing

When working with influencers or third-party platforms, healthcare providers must ensure strict compliance. Influencers must be authorised by the service provider, and all content must comply with HCSA regulations. If a healthcare provider's website contains hyperlinks to external websites with non-compliant content (such as before-and-after photos or patient testimonials), those hyperlinks must be removed immediately.

Telemedicine and Online Consultations

Healthcare institutions must be careful when using the Internet for patient consultations. The Internet cannot be used for patient consultation with any employee of the healthcare institution if the patient is not an existing patient of that institution.

Penalties for Non-Compliance

Violations of HCSA advertising rules carry significant penalties, including fines and potential damage to the institution's reputation. The Ministry of Health actively monitors compliance and has issued warning letters to healthcare providers for violations such as displaying patient testimonials on websites and social media pages.

Best Practices for Compliance

To maintain compliance while building an effective digital marketing strategy, healthcare providers should:

• Focus on educational content that builds patient trust without being overly promotional
• Ensure all claims are supported by clinical evidence
• Monitor campaigns across digital platforms to prevent compliance issues
• Work with marketing partners familiar with HCSA requirements
• Regularly review advertising materials to ensure they meet current guidelines

Healthcare providers in Singapore must balance their marketing objectives with strict regulatory requirements. By understanding these guidelines and implementing compliant strategies, clinics can effectively reach patients while maintaining ethical standards and avoiding costly penalties.