Most healthcare marketing compliance failures are preventable with a 90-second review per item. The problem is not that review takes too long - it’s that the review isn’t structured, so staff don’t know what to check. Here’s a practical 15-item checklist that covers the main FDA, FTC, HIPAA, and platform-policy categories. Use it before every publish.
FDA claim check (4 items)
1. Any disease names?
Scan for specific disease or condition names used in connection with your treatment. “Arthritis,” “depression,” “diabetes,” “cancer,” “ED,” “migraine” - any named disease paired with claimed treatment is FDA drug-claim territory. Remove the disease name or remove the claim.
2. Any “cures,” “treats,” “heals,” “prevents,” “reverses”?
Direct therapeutic verbs are drug claims. Replace with “may support,” “may help,” “has been studied for” language plus the appropriate individual-variation disclosure.
3. “FDA-approved” accurate?
Check: is the specific product FDA-approved (PMA/NDA), FDA-cleared (510(k)), FDA-registered (facility), or none of the above? The three are not interchangeable. Verify and correct.
4. Any safety absolutes?
“No side effects,” “completely safe,” “risk-free,” “painless” - absolute-safety claims. Replace with specific “most patients experience” language.
FTC substantiation check (3 items)
5. Specific numbers?
Any specific percentage, pound, inch, follicle count, or other number needs substantiation. Cite the study, or attribute as “some patients report” without the specific number, or remove.
6. “Clinically proven,” “studies show,” “research confirms”?
These phrases trigger the prior-substantiation rule. Either cite the specific study with specific findings, or rephrase as “research into [area] continues” framing.
7. Superlatives (“best,” “top,” “leading,” “most”)?
Superlative claims need substantiation. Reframe as “a leading [specialty] practice in [location]” or remove.
Endorsement and testimonial check (3 items)
8. Testimonials have typical-experience framing?
Any testimonial describing outcome must be paired with disclosure of typical experience. “Results may vary” is not sufficient - disclose what typical customers actually experience.
9. Material connections disclosed?
Paid endorsers, free-treatment endorsers, employees, family members - the material connection must be clearly disclosed in the post itself. Not in bio, not in fine print, not behind a click.
10. Celebrity or influencer content?
Apply heightened scrutiny to celebrity or influencer content. Verify the endorsement relationship is documented, the disclosure is in the post itself, and the content avoids implied-endorsement patterns if no formal relationship exists.
HIPAA and patient info check (2 items)
11. Patient authorization for info used?
Photos, stories, quotes, initials - any patient information needs documented HIPAA-compliant authorization for marketing use. Verify authorization exists in your records.
12. No unauthorized PHI visible?
Check backgrounds of photos for patient charts, names, or protected information. Check testimonials for statements that implicitly identify specific patients.
Platform-specific check (2 items)
13. Platform policy for intended channel?
Meta: before/after imagery rules, specific health-outcome claim rules. Google Ads: category restrictions, landing page compliance. TikTok: medical content guidelines. Verify the specific channel’s rules.
14. Landing page also compliant?
If the content is an ad, the landing page is in the same compliance scope. Verify the landing page meets the same standards as the ad.
Final check (1 item)
15. Would you show this to a regulator?
The gut check. If the piece of content makes you hesitate when imagining it as an exhibit in an FDA or FTC proceeding, stop and revise. Most reviewers know the answer; the checklist just creates the space to acknowledge it.
This checklist is the difference between “someone should have caught that” and “we have a process for this.” The checklist itself takes 90 seconds per item with practice. The cost of not having one is measured in warning letters.
Integrating the checklist into your workflow
- Every social post. Run through the checklist before scheduling. Items 1-10 apply to every post; items 11-14 apply depending on content.
- Every ad. Full checklist for every ad creative, including landing page review at item 14.
- Every email send. Items 1-10 at minimum; full checklist if email includes testimonials or endorsements.
- Every website page. Full checklist at launch; re-check when edits touch compliance-sensitive sections.
- Every blog post. Full checklist, with extra attention to substantiation items 5-7 for educational content making specific claims.