Fake Reviews and the FTC Rule: What Healthcare Practices Must Know

What does the FTC fake review rule ban?

The FTC’s Trade Regulation Rule on the Use of Consumer Reviews and Testimonials, in effect since October 21, 2024, bans fake reviews, buying reviews that require a certain sentiment, undisclosed insider reviews, fake “independent” review sites, review suppression and fake social media influence. It applies to medical and dental practices like any other business.

The Commission announced the final rule on August 14, 2024 by a 5-0 vote. Because it is a trade regulation rule, a knowing violation can lead the FTC to seek civil penalties in federal court. Here is what the rule prohibits, in plain terms:

• Fake or false reviews and testimonials. Writing, buying or posting reviews from people who don’t exist, including AI-generated reviews, or from people who never had the experience they describe.
• Buying positive or negative reviews. Offering money or anything of value on the condition, stated or implied, that the review express a particular sentiment.
• Undisclosed insider reviews. Reviews by owners, officers, managers or employees, and certain reviews solicited from their relatives, without a clear disclosure of the relationship.
• Company-controlled review websites. Claiming a site you control offers independent reviews of a category that includes your own services.
• Review suppression. Using baseless legal threats, intimidation or knowingly false public accusations to stop or remove negative reviews.
• Fake social media indicators. Buying bot followers or fake views to misrepresent your influence.

Note what the rule does not do. It doesn’t create a private right of action, and FTC staff guidance confirms that simply hosting reviews you didn’t write generally won’t make a practice liable. The risk sits with what you, your staff and your vendors do.

Getting compliant with the review rules

1. 1Audit current reviews
2. 2Remove insider reviews
3. 3End incentives and gating
4. 4Document your policy

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How much can a practice be fined for fake reviews?

Up to $53,088 per violation. That is the current inflation-adjusted maximum civil penalty for knowing violations of an FTC trade regulation rule, and it did not change for 2026. Because the cap applies per violation, a pattern of fake or insider reviews can add up quickly.

The figure comes from the FTC’s penalty table at 16 CFR 1.98, which lists $53,088 for violations of Section 5(m)(1)(A) of the FTC Act, the provision that covers rule violations. Federal agencies normally raise these amounts every January. For 2026, the FTC published a notice that its civil penalty amounts remain unchanged and that it will continue to apply the 2025 levels.

The FTC has started using the rule. On December 22, 2025, FTC staff sent warning letters to 10 companies about possible violations, reminding them of civil penalties of up to $53,088 per violation. The letters were not findings of wrongdoing, but they show the agency is reviewing complaints under the new rule. Bureau of Consumer Protection Director Christopher Mufarrige said fake or false reviews “are detrimental to consumers’ ability to make accurate and informed choices.”

Patients agree. In BrightLocal’s 2026 consumer survey, 97% of consumers said businesses should face some punishment for fake reviews, and 57% want businesses caught faking reviews banned from review platforms. For a practice, the reputational cost of being caught is often bigger than the fine.

What counts as a fake, insider or suppressed review for a medical or dental office?

Any review that doesn’t reflect a real patient’s genuine experience is fake, including reviews written by your team, a marketing vendor or AI. Reviews from staff or family are insider reviews unless clearly disclosed. Threatening or pressuring a reviewer to remove a truthful negative review is suppression.

In our work with 3,200+ practices, the risky behavior usually isn’t a practice buying 500 reviews from an overseas website. It’s smaller habits that feel harmless: a hygienist reviewing the office, a spouse posting from home, a vendor “seeding” a new location, or an office manager telling a patient their review is defamatory. The table sorts common scenarios.

Scenario	FTC rule	Google policy
A vendor writes reviews for a new location	Prohibited fake review	Fake engagement; removal and profile restrictions
Using AI to draft reviews posted under patient names	Prohibited fake review	Not based on a real experience
Staff or relatives review the practice without disclosure	Prohibited insider review	Conflict of interest
Gift card offered only for five-star reviews	Prohibited sentiment-conditioned incentive	Incentivized review, prohibited
Gift card offered for any review	Not barred by the rule if not tied to sentiment	Still prohibited
Threatening to sue over a truthful negative review	Prohibited suppression if the threat is baseless	Not a valid removal request
Flagging a review that is clearly about another business	Allowed	Allowed; Google may remove it
Asking every patient for an honest review	Allowed	Allowed

The middle rows trip people up. The FTC rule focuses on incentives tied to a positive or negative sentiment. Google’s Maps content policy goes further and bans content “posted due to an incentive offered by a business” in any form. Since Google is where most patients read reviews, follow the stricter rule.

If you use a marketing agency, you are still responsible for what is posted on your behalf. The FTC rule covers reviews a business knew or should have known were fake. Ask any vendor in writing how they generate reviews, and walk away from anyone who promises a specific number.

How does Google punish profiles with fake reviews?

Google removes fake reviews and can restrict the Business Profile that benefited from them. Restrictions can include blocking new reviews for a set period, unpublishing existing reviews, and showing patients a warning that fake reviews were removed. Owners are notified by email before a restriction and can appeal.

Those penalties come straight from Google’s Business Profile restrictions help page, which says restrictions apply “in addition to removing the violative reviews.” A public warning on your profile tells every prospective patient that your practice was caught, and it appears at the moment they’re deciding whether to call.

Google is also catching more of it. In an April 16, 2026 post, Google said it blocked or removed over 292 million policy-violating reviews and removed over 13 million fake Business Profiles in 2025. It also said its systems now detect specific scam patterns before posts go live and can temporarily pause new reviews on a profile during a sudden spam surge.

Repeat or severe violations can escalate. A profile with fake engagement problems invites closer scrutiny of everything else, including your business name, address and categories. If your profile has already been suspended, see our guide to Google Business Profile suspensions for doctors.

By the numbers292M+policy-violating reviews Google blocked or removed in 2025Google, 2026Doctorsinternet

Is review gating illegal?

Review gating means surveying patients first and sending only happy ones to Google. The FTC rule has no specific ban on it, but FTC staff say it could violate the FTC Act as a deceptive practice, and Google’s policy explicitly prohibits selectively soliciting positive reviews. Either way, it puts your profile at risk.

The FTC’s rule Q&A says directly that “the rule does not contain a specific prohibition against such conduct,” then points to the Endorsement Guides, which treat selective solicitation that distorts overall ratings as potentially deceptive. Google’s policy says businesses may not “discourage or prohibit negative reviews, or selectively solicit positive reviews from customers.”

Many older review tools were built around gating: a “How did we do?” screen that sends four- and five-star responders to Google and everyone else to a private form. If your system still works that way, turn the filter off. You can keep a private feedback channel, as long as every patient also gets the same public review link.

Can we ask a patient to remove a negative review?

You can contact an unhappy patient, resolve the problem and ask whether they’d consider updating their review. You cannot threaten them, pay them to remove it, falsely accuse them, or use a contract clause that forbids negative reviews. And you can never reveal health information while responding.

FTC staff guidance explicitly allows responding publicly to negative reviews, contacting customers to resolve issues and asking satisfied customers to update their reviews. What crosses the line is intimidation, unfounded legal threats or knowingly false accusations. Paying a patient to change or remove a truthful review may also violate the FTC Act.

Check your intake paperwork too. The Consumer Review Fairness Act makes it illegal to use form contract terms that restrict customers from reviewing your services, charge a fee for negative reviews, or require them to hand over rights to their review content. Some practices still have “non-disparagement” language in old patient agreements. Remove it.

HIPAA adds another layer for healthcare. In 2022, HHS’s Office for Civil Rights announced a $23,000 settlement with New Vision Dental, which disclosed patient names, treatment and insurance information in replies to online reviews. Respond in general terms and move the conversation offline. Our guide on how to get more patient reviews includes HIPAA-safe reply templates.

What must practices stop doing now?

Stop anything that creates a review without a real patient experience behind it, rewards reviews, filters who gets asked, or pressures reviewers. Then document your review process so you can show it is compliant. Use this checklist with your office manager and any marketing vendor.

1. Remove insider reviews. Ask staff, owners, relatives and vendors to delete any reviews they posted about the practice, on every platform.
2. End incentives. No raffles, discounts, gift cards or free whitening for reviews, even if any review qualifies.
3. Turn off gating. Send the same public review request to every patient who completes a visit.
4. Drop staff quotas. Google prohibits asking staff to solicit a certain number of reviews, so retire review contests and targets.
5. Audit vendors. Get written confirmation that no one creates, buys or AI-generates reviews, testimonials or followers for you.
6. Check website testimonials. Make sure each one is from a real patient, reflects their actual experience and is used with written authorization.
7. Clean up paperwork. Remove non-disparagement or review-restriction clauses from patient forms and financial policies.
8. Train on replies. No threats, no accusations, no patient details. Escalate legal concerns to counsel before responding.
9. Write it down. Keep a one-page review policy that shows how you ask, who asks and how you respond.

Our review management service is built around these rules, with request workflows that ask every patient the same way and monitoring that flags suspicious reviews early.