Can a practice reward patients for reviews under the FTC rule?

Who this is for

This is for the physician or medical professional who owns an aesthetic or cosmetic surgery practice, and/or the operations lead who runs the practice's review requests and decides whether a patient gets anything for posting one.

The Federal Trade Commission's 2024 rule on consumer reviews and testimonials answers part of the question of whether a practice can offer something for a review.¹

Here a reward or incentive means anything a practice gives for a review, such as a gift card, a credit or a discount.

Which review practices does the FTC's 2024 rule ban?

The rule bans creating, buying or selling fake or false reviews and testimonials. It bans buying reviews in exchange for what they say, or on the condition that they say it. It also bans using reviews and testimonials from company insiders who hide their relationship to the company.¹

The same rule covers three more practices. The first is a review site that a company controls while presenting it as independent. The second is what the rule calls review suppression; the rule's summary of its prohibitions names it without defining it. The third is fake indicators of social media influence.¹

For employees, the FTC limits the insider section to two cases. In the rule's words, it applies only to "testimonials by employees that the company chooses to disseminate" and to "reviews that are solicited or demanded by company officers or managers."¹

The FTC names no medical examples, but two situations common in a practice look to us like they fall under this section. One is a nurse injector's testimonial that the practice posts on its own website. The other is a practice manager asking front-desk staff to leave Google reviews. Both turn on whether the staff member's tie to the practice is hidden.

The FTC's question-and-answer page for businesses closes one workaround. The page asks whether a business can pay incentives for 5-star reviews on third-party platforms if it asks the reviewers to add a disclosure about the incentive. The answer it gives is no.²

Review gating is the common name for sending only satisfied patients to a public review site and routing unhappy ones to a private form. The rule's own summary of its prohibitions does not use that term. The summary names review suppression and does not say whether a gate counts as suppression.¹

Can a practice give patients a gift card or discount for leaving a review?

Under the 2024 rule, yes, with two conditions that the FTC spells out on its question-and-answer page. The first condition is about sentiment. The rule does not bar incentivized reviews unless there is a requirement, stated or implied, that the review express a particular sentiment.²

Implied requirements count too. In the FTC's words, "The rule prohibits businesses from implying that a review has to be positive in order for consumers to get an incentive for the review." The same page says a business cannot suggest that a review must be positive, or negative, to earn a promised incentive, even if it never says so outright.²

The second condition is disclosure, and it comes from a different law. The page goes on: "But remember that failing to disclose incentives could be a violation of the FTC Act." It points to the FTC's Endorsement Guides, the agency's guidance on endorsements, at 16 CFR 255.5(a) and (b)(6)(ii).²

A practice that gives every reviewing patient the same small credit, whatever the patient writes, sits outside the rule's ban but still has to disclose the credit. The FTC page gives no front-desk example. Our reading is that a script mentioning the credit in the same request as 5 stars could imply the credit depends on the rating, which is what the page prohibits.

Some vendors who sell review services to practices hold themselves to a stricter line than the rule. Healthcare Marketing Group (2026) tells clients, "We do not buy, write, incentivize, or gate reviews." RepuClinic (2026) tells dentists to offer "no discounts, gifts, or contests."^3,4

What did the FTC say about reviews in its 2026 TruHeight case?

In April 2026 the FTC announced action against TruHeight, for what its press release calls deceptive, unsubstantiated advertising of products said to increase height. The case is listed as In the Matter of TruHeight (Vanilla Chip LLC).^5,6

The FTC's business blog post on the case drew a lesson for other sellers. The post said people want to know whether a review is genuine and comes from an unbiased consumer, because that affects how much weight they give it. It then advised: "If a review is written or created by your own employee, a vendor, a paid endorser, or another person with ties to your company, make that clear."⁷

Medscape's 2025 article "The dirty truth behind some doctor reviews" reported that doctors trading reviews with one another may count as deceptive advertising.⁸

The blog's list is an employee, a vendor, a paid endorser, or another person with ties to the company. For a practice, staff fit the first and an agency running its marketing fits the second. Whether a colleague who refers patients counts as "another person with ties" is our reading; the blog does not say.⁷

What do surveys and studies say about patients and online reviews?

Each survey below asked patients a different question, so each data point is given with the question it answers. Two studies that set ratings against other quality measures found the ratings did not track them.

A 2019 paper in the Journal of Medical Internet Research cites a US national survey in which 59% of participants called online physician reviews "very or somewhat important" when choosing a physician. The paper reports that word of mouth from family and friends was endorsed more often than reviews.⁹

RepuGen, a review vendor, surveyed 1,426 people in 2024, and 72.71% called online reviews "a major influence" on choosing a provider. The report sets that beside 75% in 2022 and describes the change as fewer patients relying solely on reviews.¹⁰

rater8's 2025 survey, as TechTarget reported it, said 84% of surveyed patients "still use online provider reviews", and 40% said a negative review could keep them from booking.¹¹

In rater8's 2026 survey, 55% said they had avoided a provider or canceled an appointment because of online reviews; TechTarget gives 40% for 2025 and does not say whether the two waves asked the same people the same way.¹² A 2020 study indexed on PubMed Central asked what patients would do, and 58 of them (55.8%) said they would not cancel an appointment if they learned their physician's online rating was poor.¹³

The two quality studies used different yardsticks. A 2018 study in the Interactive Journal of Medical Research compared the online ratings of 41,104 physicians in 10 large US cities against physician peer review. The sample included 1,142 physicians listed as "America's Top Doctors", and the authors found no difference in mean online rating between physicians on that list and those off it.¹⁴

A 2022 paper in the Journal of Empirical Legal Studies used legal records instead of peer reputation. Its abstract reports that the online ratings of 171 Illinois hospitals were largely uncorrelated with the share of affiliated physicians who had paid malpractice claims or disciplinary sanctions.¹⁵

AI tools now sit between a patient and those reviews. rater8's 2026 survey found 47% of patients using AI to find a new provider, up from 31% at the end of 2025. rater8 also lists "reviews" for a practice among the most common search queries, at 26%.¹² The earlier 2025 survey, a separate wave, found 26% of patients said generative AI had swayed their choice of a new provider.¹¹

Rock Health's December 2025 survey of 8,000 census-matched US adults asked a broader question: whether people had ever used an AI chatbot for health information. 32% had, double the 16% from a year earlier.¹⁶

Uberall, a listings vendor, studied AI recommendations for dental practices. It reports that large dental groups made up 4.4% of the recommendations and independent practices made up 72%. Uberall explains this by saying AI recommends the practices it has the most consistent, specific information about. This is a vendor's own finding, and it covers dentistry only.¹⁷

How do practices manage their reviews today?

The American Dental Association reports that 88% of dentists surveyed by its Health Policy Institute had received online patient reviews. In a May 2019 MGMA poll with 1,287 responses, 64% of healthcare leaders said they manage their practice's online reputation and 32% said they do not.^18,19

What patients write about points back at operations. In 2020, Healthgrades and MGMA analyzed 8.4 million star reviews, 2.4 million of them with written comments. Positive reviews most often mentioned the doctor's skill or the quality of care. Negative reviews mentioned wait time, visit time and office staff up to three times more often than positive ones did.²⁰

Healthcare Marketing Group (2026) says it aims for four to eight new Google reviews a month at minimum, building toward a profile of 50 or more, by asking every patient systematically.³

Our suggestion, from the FTC's text above: the same review request goes to every patient by the same channel, and any reward is the same whatever the patient writes, with the reward disclosed. Staff and vendors who post a review name their tie to the practice.

A practice with a specific question about a gift, a contest or a review gate should take it to its own counsel. The FTC's text is one set of rules, and each review platform has its own.

About this review

We read the FTC's 2024 final rule and its business question-and-answer page. We also read the FTC's April 2026 press release, business blog post and case page on TruHeight. The rest of the reading covered peer-reviewed papers on online physician and hospital ratings, and industry surveys from MGMA, Healthgrades, the American Dental Association and Rock Health. It also took in two rater8 surveys as reported by TechTarget, Medscape's 2025 reporting, and vendor publications. All of it was read in October 2026.

We read the Journal of Empirical Legal Studies paper in its abstract only. The 2019 Journal of Medical Internet Research data point is that paper's citation of an earlier national survey. The FTC's final-rule document reports no penalty against a particular company. The TechTarget articles give no total sample size for the rater8 surveys. The retrieved record for the PubMed Central study did not include its authors or journal. The review platforms' own policies on incentives were not read. None of the sources measures how often aesthetic practices offer incentives for reviews or gate them. This is a reading of public guidance and is not legal advice.

Fractional Aesthetics is a growth strategy practice for aesthetic medical businesses.