Online reviews and public feedback have become essential to how consumers choose healthcare providers. At the same time, regulators including the Federal Trade Commission (FTC) and state attorneys general (AGs) have increased enforcement against deceptive practices that distort reviews and mislead consumers.
This enforcement pillar highlights real cases and legal precedents that illustrate the real-world consequences of deceptive review conduct, misleading consumer practices, and related violations of consumer protection laws. Healthcare decision-makers should understand not only what the FTC and other various compliance rules are but what happens when those rules are broken: investigations, settlements, injunctions, and substantial penalties.
Learn what you can do to report violations on our How to Report Fake or Manipulated Reviews page.
How To Use This Page
This page is designed for healthcare administrators and decision-makers who want to understand how online review practices can create legal and reputational risk.
The examples below are not meant to suggest that healthcare providers are routinely targeted by regulators. Instead, they illustrate how review-related conduct is evaluated when regulators do take action.
Each example highlights what triggered scrutiny, what the outcome was, and what lessons apply to healthcare organizations.
What this page does not cover
This page explains how FTC review rules generally apply to healthcare organizations. It does not provide legal advice or address every possible scenario. Providers should consult qualified counsel when evaluating specific practices.
Patterns That Can Trigger Reputation and Compliance Concerns
Reputation risk typically develops from recurring patterns rather than isolated reviews. Regulators and review platforms look for trends that suggest bias, manipulation, or non-transparent review practices. Common patterns associated with elevated compliance risk include:
- A surge in reviews over a short period without a clear cause
- Reviews predominantly from insiders or undisclosed employees
- Selective solicitation of feedback from only satisfied individuals
- Review profiles dominated by brief, low-detail comments
- Systematic discouragement or suppression of negative feedback
Federal guidance highlights that reviews written by insiders — including employees or stakeholders with a material connection — must be appropriately disclosed. Similarly, incentivized reviews that tie feedback to specific sentiments may be viewed as deceptive under the federal rule governing consumer reviews and testimonials.
Provider organizations should be aware of these patterns and proactively evaluate their review strategies to ensure they are collecting and displaying feedback transparently and fairly.
FTC Actions Focused on Fake or Misleading Reviews
FTC’s Final Rule Banning Fake Reviews and Testimonials (2024)
In 2024, the FTC finalized a comprehensive rule prohibiting fake or false consumer reviews, testimonials, and endorsements that misrepresent the reviewer’s experience or identity. The rule also bars:
- buying or selling reviews
- undisclosed insider reviews
- review suppression
- misrepresentation of independent review platforms
This rule gives the FTC explicit authority to pursue enforcement actions and civil penalties for unfair and deceptive review practices — an authority that healthcare organizations should take seriously given the heavy regulatory environment.
Sitejabber: FTC Order Against an Online Review Platform (2024)
In one of the first major enforcement actions under the new review rule, the FTC charged the online review platform Sitejabber with misrepresenting reviews collected before actual customer experience. The agency ordered Sitejabber to stop deceptive review practices and cease assisting others in misrepresenting review credibility.
Why It Matters for Healthcare:
Although not a healthcare entity, this case demonstrates how the FTC will hold review platforms accountable including those that might host healthcare reviews. It signals that platforms and the businesses that rely on them cannot escape responsibility when reviews are misused or misrepresented.
Broader FTC Enforcement Examples Relevant to Healthcare Reputation
While not all FTC enforcement actions directly involve healthcare providers, they illustrate how deceptive practices related to consumer perception, misleading claims, and review manipulation can result in significant consequences.
NextMed Telemedicine Case (2025)
The FTC took action against telemedicine provider NextMed, alleging deceptive marketing practices that included fake positive reviews and suppression of negative reviews alongside misleading health claims in the context of weight-loss treatment programs. Federal Trade Commission
Relevance:
This case is significant because it shows the FTC’s willingness to target healthcare-adjacent entities for deceptive review conduct. Even when issues extend beyond traditional product reviews, misleading testimonials and suppressed criticism carry enforcement risk.
FTC & Illinois AG – Leader Automotive Group Settlement (~$20M) (2024)
In a high-profile federal/state enforcement action, the FTC and Illinois Attorney General filed a lawsuit against Leader Automotive Group alleging that multiple dealerships engaged in deceptive practices including junk fees, add-ons, and posting fake positive reviews to boost reputation. The proposed settlement requires approximately $20 million in monetary relief and injunctive measures.
Why This Matters Beyond Automotive:
Although the Leader case involved auto dealerships, it underscores a central regulatory theme: deliberately manipulating online reputation (including fake reviews) can trigger major penalties in conjunction with consumer fraud claims. Healthcare organizations, especially large systems and multi-location operators, should recognize that deceptive reputation tactics could draw similar scrutiny.
State Attorneys General and Consumer Protection Enforcement
Notice of Penalty Offenses on Fake Reviews (FTC, 2021-present)
In ongoing enforcement efforts, the FTC issued Notices of Penalty Offenses to hundreds of companies warning them that fake reviews and misleading endorsements could result in civil penalties of up to tens of thousands of dollars per violation.
These notices raise awareness among businesses that the FTC’s fake review enforcement regime is not theoretical, it carries meaningful financial risk.
Other FTC Enforcement Contexts with Relevance to Healthcare Reputation
While not review-specific, other FTC actions illustrate broader consumer protection enforcement that healthcare organizations should monitor:
GoodRx Health Data Enforcement (2023)
The FTC fined GoodRx Holdings Inc. $1.5 million for improperly sharing sensitive health data without consent — a data protection case that reflects the Commission’s broader consumer protection reach in healthcare contexts.
Although not a review case, executives should note that consumer harms and trust issues related to digital healthcare operations are subject to federal enforcement.
Regulatory and Platform Oversight
Healthcare review activity may be evaluated by multiple external parties. The Federal Trade Commission enforces consumer protection standards related to deceptive or misleading review practices. State attorneys general may also pursue enforcement under state-level consumer protection laws.
In addition, review platforms such as Google apply their own policies and automated systems to detect manipulation, insider activity, or policy violations. Enforcement actions may include review removal, profile restrictions, or public penalties.
Reporting and External Scrutiny of Review Activity
Suspected violations related to online reviews can come from a variety of sources. Patients, family members, employees, competitors, or members of the public may report concerns when they perceive review activity as unfair, manipulated, or misleading. These reports often focus on observable trends and patterns rather than isolated comments.
Because online reviews are publicly visible, provider organizations may not always be aware of how their review practices are perceived externally until questions are raised. Proactive monitoring, transparent review collection, and clear internal policies help minimize the risk of external scrutiny and support better reputation outcomes.
Healthcare Regulatory & Professional Consequences
In addition to federal and state enforcement actions, healthcare professionals face discipline under state medical board and licensing laws for deceptive marketing, including fake reviews, under ethics standards governing advertising and truthful representation. HIPAA Times
Key Takeaways for Healthcare Decision-Makers
- Fake and manipulated reviews are now explicitly banned under the FTC’s 2024 consumer review rule. Federal Trade Commission
- FTC enforcement against platforms and entities shows regulators will act even if a company isn’t a traditional retailer or services business. Federal Trade Commission
- Joint federal/state enforcement (like the Leader Automotive settlement) demonstrates the serious financial stakes when review manipulation is part of broader deceptive practices. Illinois Attorney General
- Healthcare practices and hospitals should avoid any appearance of misleading testimony, paid positive reviews, or selective suppression — not only for compliance but for trust and legal risk management.