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What are some examples of advertisements that “amount to soliciting or encouraging the use of the licensable healthcare service provided by any licensee”?

Healthcare Services Act(Advertisement) Regulations, Contents of Advertisement

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Updated by MOH

Examples of advertisements that solicit or encourage the use of the licensable healthcare service includes:

  • “Before-and-after” treatment photos; and

  • Information that promises or suggests that the services can bring about results within a certain time period, e.g. “Instant / immediate teeth whitening”, “straight teeth in 2 weeks”.

Examples of information that solicit or encourage the use of licensable healthcare services are “promotions” which refer to free or discounted services or products provided at or by licensees, or interest-free payment plans for licensable healthcare service. Further examples include, but are not limited to advertisements with:


  • Price comparison of the usual prices and the time-limited discounted prices or advertised prices for the same or a group of licensable healthcare services provided by the licensee (licensees must only list the exact prices of their services, without indicating any prefix or description to the prices, and without a comparative listing of prices); or

  • Words or phrases such as “package”, in connection with a price discount or other mechanisms to solicit/encourage customers; or

  • Phrases such as “as low as”, and “lowest prices” when describing the price of licensable healthcare services, or stating an instalment amount for the services without stating the total price; or

  • Preferential prices for licensable healthcare services with a “validity period”; or

  • Any services provided at or by licensee that are free of charge or at a lower cost than usual, in connection with any other services advertised by the licensee; or

  • Words or phrases such as “discount”, “interest free”, “preferential rate”, “promotion”, “offer”, “complimentary”, “free”, or other words or phrases to the same effect; or

  • Information on group buying websites or websites that offer lower prices through collective group buying of licensable healthcare services; or

  • Giveaways, lucky draws, prizes, gifts and/or freebies, whether in relation to or otherwise to the licensable healthcare services; or

  • Using miles/points (e.g. membership points) to redeem a service. As miles/points can be construed as a form of alternative currency, using miles/points has a soliciting effect because the individual may perceive that he is getting the healthcare service without having to pay out of pocket for it.

To avoid doubt, patients may be informed of licensable healthcare service payment plans (e.g. instalments, package prices) only at the point of payment.


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