Articles and Case Studies

The Trouble with Testimonials

07 Nov 2018

Karen Stephens 110x137

by Ms Karen Stephens


A chiropractor was found to have used false and misleading advertising about being able to cure cancer and to have used testimonials in website advertising.

The chiropractor was given a criminal conviction, fined $29,500 and deregistered for two years. Although the claims about curing cancer were more serious than the use of testimonials, the findings in one of the hearings1included the following:

The two testimonial offences demonstrate that the practitioner took no steps to stay up to date with current professional laws and standards on advertising, and failed to understand why such material may be dangerously misleading to patients

The Law

Section 133(1)(c) of the Health Practitioner Regulation National Law states that a person must not advertise a regulated health service, or a business that provides a regulated health service, in a way that uses testimonials or purported testimonials about the service or business.

What is a testimonial?

A testimonial is a statement, review, view or feedback about a service. AHPRA advises2 that in the context of the National Law, a testimonial involves recommendations or positive statements about clinical aspects of a regulated health service.

Places that testimonials may be found include:

  • under a tab or heading ‘Testimonials’ on a practice website or information brochure
  • in the Reviews tab on a practice’s or doctor’s Facebook page
  • in comments on a practice’s or doctor’s Instagram feed.

Why are testimonials banned?

  • They are not objective or scientific.
  • One person’s outcome may not be relevant to others. 
  • They can be misleading. 
  • Patients cannot assess the validity of the claims.

Which testimonials am I responsible for?

You are responsible for reviews or testimonials which appear in advertising that you control. For example, if you are the practice owner, you control your practice’s Facebook page.

You are not responsible for removing (or trying to have removed) testimonials published on a website or in social media over which you do not have control, e.g. However, a breach of the National Law may occur if you use such a review to advertise, respond to the review or re-publish it on your website.

Google reviews are not considered by AHPRA to be within your control, whether or not you have verified your Google listing. You are therefore not required to try and remove Google reviews. However, if you respond to a Google review, this could be considered a testimonial if, for example, the response includes clinical aspects of care.

How do I decide if a particular review is allowed?

You can access AHPRA’s testimonial tool2 which helps advertisers understand which reviews can and can’t be published. Clinical aspects cannot be referred to, e.g. symptoms, diagnosis, treatment, outcome, or the skills or experience of the practitioner.

Can I edit reviews?

Editing reviews or testimonials to meet the National Law advertising requirements could be misleading or deceptive.  Recent publicity about HealthEngine,3 an online appointment booking service, altering negative patient reviews and publishing them as "positive customer feedback” led AHPRA to issue guidance4 that selectively editing reviews or testimonials may break the law.

What might happen if my advertising contains testimonials?

AHPRA’s current process, if they become aware that advrtising contains testimonials, is to write to the responsible practitioner asking them to check their advertising and correct the content to comply with the National Law. Usually a practitioner is given 60 days to do this, after which AHPRA may conduct an audit to see if the necessary changes have been made.

If an audit finds the advertising still doesn’t comply with the National Law, AHPRA can take further action such as imposing conditions on a doctor’s registration that restrict how and what they can advertise. Fines may also be imposed by a court, and the Medical Board can take disciplinary action.

Why can’t I use testimonials if my colleagues and competitors are using them?

This is like saying: “Why can’t I speed when other cars are speeding?”

Karen Stephens
Risk Adviser, MDA National


  1. HCCC v Limboro [2018] NSWCATOD 117
  2. AHPRA. Testimonial Tool:
  3. The Sydney Morning Herald, 9 June 2018:
  4. AHPRA, 13 June 2018: Selectively editing reviews or testimonials may break the law:

Practice Management, Regulation and Legislation


My Career Journey with Dr Nick Coatsworth

Dr Nick Coatsworth is an expert in health policy, public administration and a practising infectious diseases physician. He held a national role in the Australian response to COVID-19 as Deputy Chief Medical Officer of Australia, becoming one of the most recognised medical spokespeople during the pandemic. Nick engaged the Australian community through a variety of media platforms most notably as the spearhead of the national COVID-19 vaccination campaign. Dr Micheal Gannon, Obstetrician & Gynaecologist, sits down with Dr Nick Coatsworth to discuss Nick's medical career journey, and what insights and advice he has for junior doctors. MDA National would like to acknowledge the contributions of MDA National staff, Members, friends and colleagues in the production of the podcast and note that this work is copyright. Apart from any use permitted under applicable copyright law, you may not reproduce the content of this podcast without the permission of MDA National. This podcast contains generic information only, is intended to stimulate thought and discussion, and doesn’t account for requirements of any particular individual. The content may contain opinions which are not necessarily those of MDA National. We recommend that you always contact your indemnity provider when you require specific advice in relation to your insurance policy or medico-legal matters. MDA National Members need to contact us for specific medico-legal advice on freecall 1800 011 255 or email We may also refer you to other professional services.


09 Jun 2022

Career complications and contending with uncertainty

Among the many challenges of the COVID-19 pandemic for junior doctors is how to respond to medical training impacts and career uncertainty. In this podcast, Dr Caroline Elton (a psychologist who specialises in helping doctors)and Dr Benjamin Veness (a Psychiatry registrar) share advice for coping with medical training and career delays, disruptions and unknowns.


10 Aug 2020