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In-depth topic course

Advertise Your Health Service Without Breaching Section 133

Testimonials, Claims, Titles, Before-and-After Images and Social Media Done Lawfully

  • 3 CPD hoursEstimated learning time
  • 20-question assessmentPass mark 80%
  • Online, self-pacedStart any time
  • CertificateFor your CPD records

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About this course

Most practitioners never set out to break advertising law. The problem is that health advertising is held to a much stricter standard than ordinary marketing, and the rules are easy to trip over: a patient review embedded on your website, the word "specialist" in your Instagram bio, a "free first visit" with no terms, a before-and-after photo taken under different lighting, or an agency's ad that names a prescription medicine. Since the 2022 amendments to the National Law, the maximum penalty for an advertising offence is $60,000 per offence for an individual and $120,000 for a company, and Ahpra also audits practitioners' declarations that their advertising complies.

This course turns section 133 of the Health Practitioner Regulation National Law and the Guidelines for advertising a regulated health service into practical decisions. You will work through what counts as advertising, who is responsible when an agency or employer writes it, how to tell a prohibited testimonial from a lawful comment, what evidence you need for a claim, how to describe your titles and experience, how to use images and patient content, and when TGA, consumer law and the cosmetic advertising guidelines add further limits.

You finish with a structured audit checklist, rewrite examples you can adapt, a quick-reference guide for approving any advertisement, and a reflective account for your CPD record.

Who this course is for

  • Registered health practitioners in any of the regulated professions who have a website, social media presence or directory profile
  • Practice owners, directors and principal practitioners responsible for clinic marketing
  • Practice managers and marketing staff who write or approve advertising for health services
  • Employed and contracted practitioners whose names, photos or results appear in an employer's advertising
  • Practitioners offering cosmetic, weight management or other higher-risk services who need to understand where stricter rules apply
  • Practitioners who have received an Ahpra advertising letter and want to understand the requirements properly

What you’ll learn

  • Spot non-compliant advertising quickly

    Apply the five section 133 prohibitions and the Board guidelines to any web page, post, flyer or ad before it goes live.

  • Handle reviews and social media safely

    Decide which patient comments can be used, moderate or disable functions you control, and respond to reviews without breaching privacy.

  • Describe yourself accurately

    Write titles, qualifications, "Dr" usage and experience claims that match the public register and do not imply specialist status.

  • Run an advertising audit

    Use a ten-point checklist, a practice advertising policy and an agency brief to keep your advertising compliant over time.

Learning objectives

  • Explain what counts as advertising a regulated health service and who is responsible for it.
  • Apply the five prohibitions in section 133 of the National Law to everyday advertising.
  • Distinguish prohibited testimonials from lawful patient comments and manage reviews and social media.
  • Support effectiveness claims with acceptable evidence and present prices accurately.
  • Describe titles, qualifications and experience lawfully, including the restriction on "surgeon".
  • Use before-and-after images and patient content only with genuine, comparable images and valid consent.
  • Recognise when TGA, consumer law and cosmetic advertising rules also apply.
  • Respond to Ahpra advertising correspondence and audit practice advertising systematically.

Scenarios covered

Practice situations you reason through, step by step, in the course.

  • The review widget on the home page

    A psychology practice embeds its live Google reviews on its website, including comments about recovering from depression. We work through why this becomes the practice's own testimonial, and what to do with reviews on platforms you do and do not control.

  • The "specialist" in the bio

    A general dentist describes himself as an "implant specialist" and a GP is listed as a "skin cancer specialist". We look at specialist titles, endorsements, "special interest" wording and the restriction on the title "surgeon".

  • The free first visit

    A clinic promotes a free assessment and recovers the cost through higher follow-up fees. We rewrite offers so the terms are clear and the inducement does not drive unnecessary use.

  • The condition list

    A clinic's website lists asthma, colic and ear infections as conditions it treats. We apply Ahpra's guidance on acceptable evidence and show how to describe services accurately instead.

  • The before-and-after post

    A smile makeover photo has brighter lighting and lipstick in the "after" shot. We set out the standards for genuine, comparable images and the consent you need to use them.

  • The letter from Ahpra

    An osteopath fixes the two pages named in a compliance letter but leaves the same claims on Facebook. We walk through how to respond, what to fix and how to prevent recurrence.

Course contents

8 sections, 33 lessons, then the final assessment.

  1. Section 1: What Counts as Advertising and Who Is Responsible4 lessons
    • 1.1 Why Health Advertising Is Regulated Differently
    • 1.2 What Is, and Is Not, Advertising
    • 1.3 Who Is the Advertiser?
    • 1.4 The Layers of Law That Apply
  2. Section 2: Section 133: The Five Prohibitions5 lessons
    • 2.1 False, Misleading or Deceptive Advertising
    • 2.2 Gifts, Discounts and Other Inducements
    • 2.3 Testimonials: The Prohibition in Brief
    • 2.4 Unreasonable Expectation of Beneficial Treatment
    • 2.5 Indiscriminate or Unnecessary Use
  3. Section 3: Testimonials, Reviews and Social Proof4 lessons
    • 3.1 Clinical and Non-Clinical Statements
    • 3.2 Reviews on Your Own Channels and on Third-Party Sites
    • 3.3 Editing, Curating and Engaging with Reviews
    • 3.4 Influencers, Ambassadors, Staff and Patient Content
  4. Section 4: Claims, Evidence and Pricing4 lessons
    • 4.1 Acceptable Evidence for Effectiveness Claims
    • 4.2 Words and Formats That Cause Problems
    • 4.3 Condition Lists, Comparisons and Superiority Claims
    • 4.4 Fees, Medicare, Health Funds and Gaps
  5. Section 5: Titles, Qualifications and Specialist Claims4 lessons
    • 5.1 Protected Titles and Holding Out
    • 5.2 Specialist Registration, Endorsements and Areas of Interest
    • 5.3 The "Dr" Title and Post-Nominals
    • 5.4 The Restricted Title "Surgeon"
  6. Section 6: Images, Before-and-After and Digital Content4 lessons
    • 6.1 When Images Mislead
    • 6.2 Standards for Before-and-After Images
    • 6.3 Consent and Privacy for Patient Images
    • 6.4 Video, Filters, AI-Generated Content and Stock Images
  7. Section 7: Therapeutic Goods, Consumer Law and Higher-Risk Areas4 lessons
    • 7.1 Advertising Services That Involve Therapeutic Goods
    • 7.2 The Australian Consumer Law
    • 7.3 Cosmetic Procedures: Stricter Rules
    • 7.4 Vulnerable People and Sensitive Health Areas
  8. Section 8: Compliance, Enforcement and a Compliant Practice4 lessons
    • 8.1 How Ahpra Enforces the Advertising Rules
    • 8.2 Responding to an Advertising Letter or Notification
    • 8.3 Auditing Your Advertising
    • 8.4 Policies, Sign-Off and Working with Marketing Agencies
  9. Final assessment and written reflection20 questions

Assessment and certificate

  1. Work through the course

    Study each section at your own pace, including the case illustrations and apply-it questions.

  2. Pass the assessment

    20 scenario-based questions. You need 16 correct (80%) to pass.

  3. Write your reflection

    A short written reflection on how the learning applies to your own practice.

  4. Download your certificate

    Shows your name, the course, the date and 3 CPD hours. Anyone can check it on our verification page.

What you keep for your CPD records

  • Certificate of completion recording approximately 3 hours of learning time, to record against your CPD plan
  • A written reflective account on your own advertising risks and the changes you will make
  • A ten-point advertising audit checklist and quick-reference approval guide
  • Rewrite examples and model phrases for offers, titles, review responses and claims

How certificates and CPD records workVerify a certificate

Primary sources

The course is built on these official documents. Check them for the current version.

Questions about this course

Is this course recognised by Ahpra or a National Board?

No. This course is not accredited, not approved and not endorsed by Ahpra or any National Board, which do not assess CPD courses of this kind. It is independent education designed to align with the National Law and the Board guidelines. Record the actual time you spend against your CPD plan and decide for yourself whether it fits your learning needs. If you have a condition or undertaking about advertising, check with Ahpra or your Board, and your lawyer or MDO, before relying on any course.

Can I use Google reviews on my clinic website?

Only if they do not refer to clinical aspects of the service. Reviews about symptoms, diagnosis, treatment or outcomes become testimonials when you use them in your advertising, including through embedded review widgets. Non-clinical comments about service, punctuality or communication can be used if they are complete and not selectively edited.

Do I have to get patient reviews removed from Google?

Generally no. Ahpra's guidance says advertisers do not have to remove reviews on third-party sites they do not control. The risk arises when you use or engage with them to promote your service, for example by reposting, embedding or quoting them.

Can I call myself a specialist if I only treat one area?

Not unless you hold specialist registration (or the relevant endorsement) in that field. Words such as "specialist", "specialises in" or "specialised" are likely to mislead. Accurate wording such as "special interest in" or "experience in" is safer, provided it is true.

What are the penalties for breaching the advertising rules?

Since the 2022 amendments to the National Law, the maximum penalty for an advertising offence is $60,000 per offence for an individual and $120,000 per offence for a body corporate. Registered practitioners can also face conditions on their registration or disciplinary action. Ahpra uses a risk-based approach, and most low-risk matters start with a compliance letter.

Can I post before-and-after photos?

Before-and-after images are not banned under the general guidelines, but they must be genuine, comparable in lighting, angle and presentation, unedited, accompanied by context, and used with the patient's separate, documented consent. Cosmetic advertising has stricter additional rules. The course sets out the standards in detail.

Does this course cover cosmetic advertising?

It introduces the cosmetic surgery and higher risk non-surgical cosmetic advertising guidelines and explains how they add to the general rules. For a full treatment of cosmetic practice, including patient selection, consent and cooling-off periods, see our companion course on cosmetic procedures.

How long does the course take and how is it assessed?

It is designed for about 3 hours of learning, including the activities, reflection and a 20-question scenario-based assessment. The pass mark is 16 out of 20 (80%), and you can review the course and try again if needed.

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