Social media

Social media for a health practice: the FTC endorsement rules for staff, patients and influencers

The 2023 Endorsement Guides reach every post where someone with a connection to your practice praises it. Here is what counts as a connection, how to disclose it, and what nobody may say.

By Mariya Di Luzio, Founder and Creative Strategist · Published September 29, 2026 · 5 min read

The short answer

When anyone with a connection to your practice posts about it, whether a paid influencer, a patient given a free session or your hygienist, the connection must be disclosed clearly in the post itself.¹² The practice is also responsible for health claims made in those posts, and must be able to prove them as if it had said them directly.⁴

Key takeaways

A material connection includes payment, free or discounted services, employment, and family or personal ties.⁴
Put the disclosure in the post, video or image itself. "#ad" works; "#sp", "#partner" or "thanks [brand]" alone do not.¹²
Platform disclosure tools help but do not settle the question. The FTC places the responsibility on the brand and the endorser.¹³
A patient’s result is read as typical unless you can prove it is, or state what patients generally experience.⁴
The practice should train and monitor anyone it asks to post, not just hope they get it right.¹

What the Endorsement Guides are, and why they reach a small practice

The Guides Concerning the Use of Endorsements and Testimonials in Advertising, at 16 CFR Part 255, explain how the FTC applies its ban on deceptive advertising to reviews, testimonials and influencer posts. The Commission approved the current version 3-0 on June 29, 2023.³ That revision added a formal definition of "clearly and conspicuously", addressed fake reviews and employee endorsements more directly, and noted that platform disclosure tools may not be enough.³

There is no size threshold. A three-chair dental office whose front desk posts "best dentist in town" on Instagram is in the same position as a supplement brand paying a creator. The Guides are about the connection and the claim, not the budget.

Who has a material connection to your practice?

The Guides say a connection must be disclosed when it "might materially affect the weight or credibility of the endorsement" and is not something the audience would reasonably expect.⁴ They list business, family and personal relationships, monetary payment, and free or discounted products "regardless of whether the advertiser requires an endorsement in return".⁴ Early access and the chance of winning a prize can count too.⁴

Who is posting, and whether the FTC expects a disclosure
Who posts about the practice	Connection	Disclosure needed?
Paid local influencer	Payment	Yes, in the post
Influencer given a free treatment or package	Free service	Yes, even if no post was required
Staff member on a personal account	Employment	Yes, even if the profile names the employer
Owner’s spouse or relative	Family	Yes
Patient entered in a giveaway for posting	Chance of a prize	Yes
Patient who paid full price and posted unprompted	None	No

The staff row catches most practices. The FTC’s FAQs say an employee should disclose the relationship in the post even when it is listed on their profile, because followers may never see the profile.¹

How should the disclosure look?

The FTC’s guide for influencers asks for plain words such as "advertisement", "ad" or "sponsored", placed where people will see them with the endorsement, not buried in a profile, at the end of a caption, or behind a "more" link.² For images and Stories, superimpose it on the image. For video, put it in the video itself, not only in the description, and repeat it during a live stream.²

The FAQs name the weak versions: "#sp", "#partner" and "thanks [brand]" on their own are ambiguous.¹ For a practice, a short plain sentence beats a hashtag. "I work at Harbor Chiropractic" or "Harbor Chiropractic gave me this adjustment free" is clear to anyone.

Platforms have their own switches. YouTube asks creators to tick the paid promotion box, which adds a label at the start of the video, and states that creators and their partners "are also responsible for understanding and complying with all applicable legal requirements".⁵ Other platforms offer similar labels. Use the label and also say it in words; the FTC places responsibility with the influencer and the brand, not the platform.¹³

The part that matters more for health: what the post says

Disclosure fixes the connection. It does not fix the claim. The Guides say an advertiser "must possess and rely upon adequate substantiation, including, when appropriate, competent and reliable scientific evidence" for claims made through endorsements, just as if it had made them itself. They add: "Consumer endorsements themselves are not competent and reliable scientific evidence."⁴

So an influencer saying your acupuncture "cured my migraines" is your claim, and it needs the same proof as if it were on your homepage. The rules for that proof are in health claims on a practice website.

Results are the second trap. A post describing one patient’s experience on a key attribute "will likely be interpreted as representing that the endorser’s experience is representative" of what others will get.⁴ If you cannot show that, the post must clearly state what people generally experience.⁴ "Results not typical" alone does not do it. For health practices, my position is to keep patient stories about the experience of care (how they were treated, how the visit ran) rather than outcomes. It is safer, and it is what prospective patients want to know anyway.

Your job as the practice: train, check, fix

The FAQs say advertisers need reasonable programs to train and monitor the people who post for them, including periodic checks and, where feasible, approving posts before they go up.¹ For a practice that means:

A one-page written policy for staff: disclose you work here in every post about the practice, never describe a patient, never promise a result.
A short brief for any influencer or ambassador, with the exact disclosure wording and a list of claims they may not make.
A monthly search of your practice name on each platform to catch posts that miss the disclosure.
A plan to ask for corrections, and to stop working with anyone who repeats the problem.

Patient privacy sits on top of all of this. A staff post that shows a patient or mentions their treatment is a HIPAA question as well as an FTC one, covered in responding to reviews without breaking HIPAA. Testimonials used on your own site follow the rules in testimonials and social proof.

Reviewing social profiles, staff policy and claims together is part of a technical and compliance rebuild. This post explains FTC guidance as published. It is not legal advice.

Questions practice owners ask

Do my employees need to disclose when they post about the practice?

Yes. The FTC says employees should disclose their relationship in the post itself, even if their profile names the employer, because followers may not see the profile.

Is the Instagram paid partnership label enough on its own?

Not necessarily. The FTC says built-in platform tools may not be sufficient and that responsibility rests with the brand and the endorser. Use the label and also state the connection in plain words in the post.

If I give an influencer a free treatment but do not require a post, is that a connection?

Yes. The Endorsement Guides list free or discounted products and services as material connections regardless of whether a post is required in return.

Can a patient share their results on our social media?

Only with written permission, and only if the practice can substantiate that the result is typical or the post clearly states what patients generally experience. Posts about the experience of care are safer than posts about outcomes.

Which hashtag should we use?

The FTC accepts plain words such as ad, advertisement or sponsored placed where people will see them. Abbreviations like sp, collab or partner on their own are considered unclear.

Sources, and how much weight each one carries

Federal Trade Commission, "FTC’s Endorsement Guides: What People Are Asking", business guidance.
Official regulator guidance. Covers employee disclosures, hashtag wording, platform tools and advertiser monitoring.
Federal Trade Commission, "Disclosures 101 for Social Media Influencers", business guidance.
Official regulator guidance on when and how to disclose on images, video and live streams.
Federal Trade Commission, "Federal Trade Commission Announces Updated Advertising Guides to Combat Deceptive Reviews and Endorsements", press release, June 29, 2023.
Official regulator announcement of the 2023 revision and its main changes.
Electronic Code of Federal Regulations, 16 CFR Part 255, Guides Concerning the Use of Endorsements and Testimonials in Advertising, sections 255.2 and 255.5.
The Guides themselves. Primary source for material connections, substantiation and typical results.
YouTube Help, "Add paid product placements, sponsorships and endorsements".
Platform policy from the operator. Binding on YouTube uploads, not a law.

This article is about marketing, website and compliance practice. It is not medical or legal advice, and nothing in it is intended to diagnose, treat, cure or prevent any disease. For a decision about your own practice, speak with a qualified attorney or the relevant regulator.

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