Marketing Communications Advisory

These guidelines have been prepared by the University Healthsystem Consortium (UHC).

1. We will be honest, accurate and truthful
2. We will verify any data we use and substantiate any claims that we make.
3. We will identify year(s) when citing an award, rating or accreditation.
4. We will include all material information when citing clinical outcomes or prices.
5. We will disclose any material vendor connections, fee arrangements or potential conflicts of interest.
6. We will identify our organizational affiliation when issuing statements or posting comments.
7. We will follow Federal Trade Commission (FTC) guidelines regarding the use of endorsements and testimonials.
8. We will protect use of our brand by partner organizations or vendors and we will respect our partners’ brands.
9. We will ensure that co-branded materials correctly characterize the organizational relationship.
10. We will use Institutional Review Board (IRB)-approved language and disclosures in clinical study recruitment and advertising.

Awards, Ratings, Accreditations

• Disclose context of the award, rating or accreditation
• Discourage payment of fees to awarding, rating or accrediting entities
• Include the date when an award/rating was received
• Objectively measure and document any comparisons between organizations

Clinicians in Marketing Communications

• Substantiate claims regarding clinician skills or training
• When including non-employed physicians in marketing materials ensure piece is organization oriented
• Provide choice of clinicians for referral services

Price Information

• Provide accurate and substantiated information
• Communicate all material fees if it is likely that the patient will need additional screenings or tests
• Include the statement “Depending on results, additional screenings may be required” where appropriate

Ethical Considerations

• Do not use fear or promote unnecessary use of health care services
• Avoid using superlatives or emotional appeals unless substantiated
• Do not define patients solely by their disease

Clinical Study Advertising

• Use Institutional Review Board (IRB)-approved language for ads/materials
• Discuss promotional guidelines with industry representatives
• Ensure brand/logo marketing guidelines are known and used by all staff

Social Media

• Identify organizational affiliation in any profiles
• Ensure pledge and implications for social media are known and used by all staff
• Ensure online medical advice is consistent with general doctor/patient standards

Endorsements and Testimonials of Our Organization

• Reflect the endorser’s opinions, beliefs or experiences
• Ensure rephrasing does not distort endorser’s views or opinions
• Substantiate any claims
• Ensure experts possess appropriate qualifications
• Identify pseudo-testimonials by actors as such

Business-to-Business: Endorsement of Other Organizations

• Disclose any relationship, fee arrangements or potential conflicts of interest
• Substantiate any claims
• Protect organization brand since use by a vendor/business may risk the organization’s reputation and/or tax-exempt status

Blogger Advertising

• Ensure bloggers disclose if compensation, free care or other benefits were received for endorsements or reviews
• Provide guidance, training and product/service information to bloggers to ensure honest, substantiated claims
• Disclose any material connections between blogger and the organization

^{Guidelines based in part on discussions of the UHC Chief Marketing Officer Council; SHSMD Advisory; Principles and Practices for Marketing Communications in Hospital and Health Systems 2010; and FTC Guidelines Concerning the Use of Endorsements and Testimonials in Advertising, 2009. While every care has been taken to ensure that the content of the Marketing Communications Advisory (“Advisory”) is useful, timely and accurate, by using the Advisory, you assume all risk and UHC staff have no legal liability or responsibility for any loss or damage arising from your reliance on the Advisory. Further, the Advisory is not meant to serve as the sole guideline for your marketing communications. You may need to seek consultation from your organization’s marketing and legal authorities and apply your own organization-specific policies and procedures. You should not rely on the content of this Advisory without evaluating your specific requirements.}