Dental reputation management: what the FTC review rule allows

What to take away

The rule's formal name is the Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, codified at 16 CFR Part 465. The FTC announced it in August 2024, and it took effect on October 21, 2024. It applies to dental practices, not only to review platforms. It sits on top of dental board advertising rules, HIPAA and each platform's policy. Getting dental reputation management right first explains why set-up decisions outlast any single review.

What the FTC review rule prohibits

The FTC rulemaking page on consumer reviews and testimonials carries the final rule and its status. It reaches the business being reviewed, not only the platform hosting the review. Penalties accrue per violation, so five bought reviews can become five counts.

On incentives, the FTC's final rule prohibits compensation or other incentives conditioned on the writing of consumer reviews expressing a particular sentiment, either positive or negative.

Incentives: what is allowed and what must be disclosed

The rule bans one thing outright: giving or promising anything of value in exchange for a review that expresses a particular sentiment. A discount for a five-star rating breaks it. So does a prize draw open only to patients who leave positive feedback.

A reward that does not depend on what the review says is not banned by the rule. The FTC's separate Endorsement Guides, at 16 CFR Part 255, still expect a clear disclosure of any material connection between the reviewer and the practice. A reviewer who received a free whitening kit should say so.

The suppression point has a narrow edge. The rule targets a site that claims to show all or most reviews while it quietly drops the low-rated ones, and it bars using threats or unfounded legal claims against reviewers. Moderating abusive content under a clear policy is different.

In short, the rule governs what a practice may offer, and the Endorsement Guides govern what readers must be told. Many dental boards go further and restrict rewards for patient testimonials, so check yours before offering anything.

Review gating and the selective ask

Review gating is the practice where satisfied patients are sent to Google and unhappy ones to a private form. Google's policy bars selectively soliciting positive reviews, and a review set built that way can mislead readers.

Invite a defined group in neutral language and accept the rating that follows. Do not approach only the patients you expect to be pleased. A neutral ask is one sentence that requests honest feedback about the visit and offers one review link.

If a review raises an urgent safety concern, preserve the post and follow your escalation route. Do not assess clinical care in a public thread.

What dental boards add on top

US state dental boards generally require advertising and testimonials to be truthful and substantiable. Examples include the Dental Board of California, which enforces Business and Professions Code section 651, and the Texas State Board of Dental Examiners. Ontario's Royal College of Dental Surgeons publishes advertising and social media guidance that bars releasing patient information without consent.

Board rules differ by state and province, so check your own board before copying a competitor's review policy. In Canada, the privacy rules that apply to patient information are covered in PIPEDA and PHIPA guidance.

The practical effect is that a review policy has three layers: the FTC rule, the board's advertising rules, and each platform's own terms. A practice has to satisfy all three at once.

HIPAA limits on what you can say in a reply

A public reply is a disclosure. The HHS HIPAA Privacy Rule overview sets the baseline for using and disclosing protected health information. Confirming that a reviewer is your patient, naming a treatment or citing an appointment date all qualify.

A safe reply stays short, sounds the same for praise and criticism, and never quotes clinical notes:

Thank you for the feedback. We take every concern seriously and want to look into it. Please contact our office manager at the number on our website so we can review the details with you directly.

When a review can come down

Google's policy on prohibited and restricted content sets out which reviews can be reported and how. Grounds include fake engagement, conflicts of interest, off-topic content and spam. A negative review from a real patient is not on that list.

Documentation improves the odds. Keep appointment records, message threads and dated screenshots. If you think a review is defamatory, treat legal action as a last resort. The FTC says you can threaten legal action if you have a legitimate basis for doing so.

Unfounded legal threats against reviewers are exactly what the FTC rule calls suppression. The false Google review guide shows how to report one without crossing that line.

Turning a review into marketing copy

Quoting a review on your website or in an ad raises a second question. HIPAA needs written authorization before a patient testimonial is used for marketing. Review quotes deserve the same scrutiny as any other claim, so keep to the dental advertising rules that apply to your practice.

Never trim a caveat. Dropping "the wait was long" from an otherwise happy quote misleads readers.

Keeping records that survive a complaint

Every answered question should carry an owner, a date and a next review point. Store the template version sent, the reply approved and the platform response. That record shows an honest process when a complaint arrives.

Common questions