What FTC, State Medical Boards, and ADA Actually Require From Your Medical Practice Website

The Federal Trade Commission's truth-in-advertising framework applies to all commercial speech, including medical practice websites. For healthcare providers, the core requirement is straightforward but demanding: every claim about treatments, outcomes, or services must be truthful, non-deceptive, and substantiated before publication.

What "substantiation" means for medical claims: The FTC expects "competent and reliable scientific evidence" supporting health-related claims. For medical practices, this typically means peer-reviewed studies, clinical trial data, or established medical consensus. Anecdotal evidence from your practice—even if genuinely observed—doesn't meet this standard.

• Prohibited: "Our stem cell therapy reverses arthritis" (unproven claim)
• Permitted: "We offer stem cell therapy. Research is ongoing regarding its effectiveness for various conditions." (factual statement with appropriate context)

The FTC has specifically targeted healthcare providers making unsupported COVID-19 claims, weight loss guarantees, and cancer treatment promises. Enforcement actions result in consent orders, fines, and required corrective advertising.

Testimonials and endorsements require disclosure. If a patient received any compensation (including discounts) for a testimonial, you must disclose this relationship. More importantly, testimonials cannot claim atypical results without clearly disclosing that outcomes vary. The FTC's Endorsement Guides were updated in 2023 with stricter requirements for health-related testimonials.

This is general guidance—consult with a healthcare attorney for advice specific to your practice and claims.

While FTC rules apply nationally, state medical boards add jurisdiction-specific advertising restrictions that often exceed federal requirements. These rules vary significantly—what's permitted in Texas may violate California regulations.

Common state-level restrictions include:

• Specialty claims: Many states prohibit advertising a "specialty" unless you hold board certification recognized by ABMS or AOA. Some states require disclosure of certification status.
• Guarantee prohibitions: Most state boards prohibit any language suggesting designed to outcomes ("We guarantee you'll walk pain-free")
• Comparative claims: Restrictions on claiming superiority over other physicians or practices
• Testimonial limitations: Some states require specific disclaimers; others restrict testimonials about medical outcomes entirely
• Before/after photo rules: Particularly strict for plastic surgery and dermatology—some states require untouched photos with identical lighting and positioning

Enforcement happens through complaint-driven investigations. A competitor or dissatisfied patient files a complaint, the board investigates, and violations can result in reprimands, fines, license conditions, or in serious cases, license suspension.

Multi-state practices face compounded complexity. If physicians are licensed in multiple states, advertising may need to satisfy the most restrictive jurisdiction's rules.

We recommend maintaining a compliance matrix tracking each state where you advertise and the specific rules that apply. This becomes part of your content review process before publication. Verify current rules with your state medical board—regulations change, and this general guidance may not reflect recent updates.

The Americans with Disabilities Act Title III requires places of public accommodation to be accessible to people with disabilities. Federal courts have increasingly held that websites constitute extensions of physical locations—meaning your medical practice website may need to be accessible under ADA.

Why medical practices face elevated risk: Healthcare is considered essential, making inaccessible medical websites particularly problematic from an ADA perspective. Plaintiff's attorneys have specifically targeted healthcare providers in accessibility lawsuits because courts view medical access as fundamental.

WCAG 2.1 AA has emerged as the de facto standard. While ADA doesn't specify technical requirements, courts and settlement agreements typically reference Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. Key requirements include:

• Alternative text: All images need descriptive alt text (critical for diagnostic images, staff photos, procedure illustrations)
• Keyboard navigation: Every function must work without a mouse
• Color contrast: Text must be readable against backgrounds (4.5:1 ratio for normal text)
• Form accessibility: Appointment request forms need proper labels, error identification, and screen reader compatibility
• Video captions: Patient education videos require captions and ideally transcripts

Typical demand letters seek $10,000-$25,000 settlements plus attorney's fees. Defending against these suits often costs more than settling, which perpetuates the litigation cycle.

Accessibility also affects SEO—alt text, heading structure, and proper HTML all contribute to search engine understanding of your content. Accessible sites often rank better because they follow technical best practices that search engines reward.

Patient testimonials create the most frequent compliance conflicts for medical practice websites. They're powerful for conversion and local SEO, but regulations severely restrict what you can publish and how.

The layered compliance problem:

• FTC: Testimonials cannot imply typical results unless you can substantiate that claim. Atypical results require clear disclosure.
• State medical boards: Many prohibit testimonials about medical outcomes entirely. Others require specific disclaimer language.
• HIPAA: Publishing testimonials requires proper authorization, and even then, you cannot respond to negative reviews in ways that confirm treatment details. (See our HIPAA-compliant SEO guide for review response protocols.)

Safer approaches for compliant testimonials:

• Focus on service experience rather than medical outcomes ("The staff made me feel comfortable" vs. "My back pain disappeared")
• Use aggregate descriptions rather than individual outcome claims ("Patients report high satisfaction" with link to third-party survey)
• When using outcome testimonials, include substantive disclaimers: "Results vary. This patient's experience may not be typical."
• Never incentivize testimonials without disclosure—discounts, free services, or other compensation require clear identification

Third-party review platforms (Google, Healthgrades) provide some insulation because you don't control what patients write. However, solicitation practices still must comply with state rules, and your responses remain subject to HIPAA.

Have your testimonial authorization forms and review solicitation practices reviewed by a healthcare attorney familiar with your state's specific rules.

Compliance constraints shape what content you can create and how you can optimize it. The practices that build sustainable SEO strategies incorporate compliance checkpoints into their content workflow rather than treating compliance as an afterthought.

Pre-publication review process:

1. Claim audit: Every health claim needs substantiation. If you can't cite peer-reviewed evidence, reframe as general information or remove.
2. Testimonial check: Review against both FTC guidelines and your state's specific rules. Add required disclaimers.
3. Specialty/credential verification: Confirm all specialty claims match board certifications. Use precise credential language.
4. Accessibility review: Run automated tools (WAVE, aXe) and conduct keyboard-only navigation test.
5. Before/after photo compliance: Verify photos meet your state's requirements for consistency and lack of digital enhancement.

How this affects SEO strategy:

• Keyword targeting shifts toward informational content. Educational content about conditions faces fewer restrictions than treatment claims, making it safer and often more linkable.
• Service pages require careful language. "We treat back pain" is factual. "We eliminate back pain" implies a guarantee. Optimize for what you can truthfully claim.
• Local SEO becomes proportionally more valuable. GBP optimization, local citations, and review management face fewer content restrictions than website claims.

The practices we've worked with find that compliance-first content strategy actually improves E-E-A-T signals. Substantiated claims with proper sourcing, clear credential disclosure, and accessible design all contribute to the trustworthiness that Google's quality raters evaluate.

For implementation guidance, see our medical practice SEO checklist which includes compliance checkpoints at each stage.

Understanding what actually triggers enforcement helps prioritize compliance efforts. Based on public enforcement actions and industry patterns, certain content types generate disproportionate regulatory attention.

High-risk content categories:

• Weight loss claims: The FTC actively monitors and has pursued numerous medical practices making unsupported weight loss guarantees
• Regenerative medicine: Stem cell, PRP, and similar emerging treatments face intense scrutiny. Outcome claims without substantial clinical evidence invite FTC action.
• Cosmetic procedure photos: Manipulated before/after images trigger state board complaints. Competitors often file these reports.
• False specialty claims: Advertising a specialty you don't hold board certification for is straightforward grounds for disciplinary action
• designed to outcomes: Any language implying designed to results violates most state board rules

Who files complaints:

• Competitors: Other physicians in your market monitor advertising and report violations
• Dissatisfied patients: Complaints often start as malpractice concerns but expand to include advertising claims that weren't met
• ADA plaintiffs' attorneys: Systematic scanning of healthcare websites for accessibility violations
• FTC monitoring: The agency conducts health advertising sweeps, particularly around trending treatments

Typical consequences:

• State board: letter of reprimand, required corrective advertising, fines ($1,000-$25,000 typical), license conditions
• FTC: consent order requiring substantiation, prohibited future claims, civil penalties in serious cases
• ADA: settlement demands ($10,000-$25,000), injunctive relief requiring website remediation, attorney's fees

For medical practices pursuing regulation-aware SEO, compliance risk assessment should inform which content investments to prioritize and which claims to avoid entirely.