Why We Can’t Show You More
Singapore has often boasted about being pioneers and first adopters of new technology. Yet, while our regulatory bodies try so hard to keep the medical and dental professions in line, they have lost sight of innovative, forward-looking practices in the region which have moved ahead of us.
Meanwhile, the system here is so cautious about misleading advertising that any form of creative publicity can fall foul of regulations. The following regulations can be summed up with the single sentence “only the boring stuff are allowed”.
PRIVATE HOSPITALS AND MEDICAL CLINICS (PHMC) (PUBLICITY) REGULATIONS
2.4 Regulation 4(1)(b) states that – “The publicity must not be offensive, ostentatious or in bad taste such as to undermine the honour and dignity of the medical, dental or nursing profession.”
2.4.1 Publicity that is considered “ostentatious” would include, but not limited to, the following:
(a) Any photo showing a person performing a procedure or administering a treatment;
(b) Any photo of a doctor, dentist or nurse exceeding ‘passport’ size (i.e. 35mm wide by 45mm high);
(c) Any photo of a celebrity/ media figure (with/ without explicitly identifying the celebrity/ media figure);
(d) HCI creating/ maintaining websites in a manner that attracts undue public’s attention (e.g. HCI having multiple websites with similar contents).
2.4.2 Publicity that is considered “in bad taste” would include, but not limited to, the following:
(a) Any content featuring obscene or repulsive pictures or words, or having sexual/ indecent connotations;
(b) Any content featuring/ implying association between the medical service/ profession and any non-medical/ non-dental service (except for other mainstream healthcare services such as allied health services, pharmacy and optometry) or any traditional, complementary or alternative health care service/ practice;
(c) Any content featuring/ implying endorsement by the HCI of an entity/ person that is not a licensed HCI or any service provided by such other person;
(d) Any content featuring a service that is not provided in local mainstream medicine;
2.5.1 HCIs shall not feature “before and after” treatment pictures/videos/ information or only “after” treatment pictures/videos/information in their publicity. Such pictures/videos/information “create an unjustified expectation from the treatment provided” as they pertain only to anecdotal cases, and not all patients will see the same results after treatment.
2.5.2 HCI shall not advertise/ publicise that its services can bring about results within a certain time period or within a specified number of sessions (e.g. “instant/ immediate teeth whitening”, “botox in 5 minutes”, “straight teethin 2 weeks”, “see results after 1 treatment session”, “accurate diagnosis for the first time”). Such information may “create an unjustified expectation from the treatment provided” as not all patients undergoing the services provided can achieve the same results after the stated time period.
2.5.3 Any pictures/videos/information implying (with/ without descriptions) that a person is/ will be healthier or less ill, aesthetically better or in a better state of general well-being after receiving the HCI’s services.
2.5.4 The licensee of the HCI shall not feature any celebrity/ media figure (with/ without identifying the celebrity/ media figure) in their publicity materials as this would amount to creating an unjustified expectation for the services provided by the HCI, which is a contravention of Regulation 4(1)(c)(i).
In addition, even though Complementary and Alternative Medicine (CAM) is allowed in Singapore, mainstream medicine cannot be combined with CAM in the same clinic. “Dental spas”, for instance, are posh and affable places in Thailand. In Singapore, they are embarrassing misnomers.
High room rates? High running costs for clinics? More admin work for clinicians? Manpower (nursing) shortage? Regulations to ensure clinics must look like clinics? Restrictions to advertising? Medical tourism in Singapore? Dream on.