What Should Doctors Do Now After the New NMC Guidelines?
A doctor's professional communication has changed significantly with the growth of websites, social media, digital platforms, and online healthcare content. Doctors and hospitals now communicate with patients not only through traditional channels, but also through Instagram, YouTube, websites, and other digital platforms. Against this background, the National Medical Commission (NMC) has issued the Guidelines on Ethical Advertising and Public Communication by Hospitals/Medical Institutions and Registered Medical Practitioners.
The guidelines have immediate effect and seek to preserve the dignity of the medical profession, prevent the commercialisation of healthcare, protect patients from false or misleading medical claims, and ensure that healthcare communication remains factual, ethical, transparent and evidence-based. For doctors, the practical issue is no longer simply whether they can maintain an online presence. The more important question is: How should doctors communicate with the public while remaining within the ethical framework prescribed by the NMC? This article looks at the practical steps doctors and healthcare institutions should consider in light of the new guidelines.
1. Start With a Review of Your Existing Communication
The first practical step is to review what is already being communicated publicly. The NMC guidelines cover communication through social media, digital platforms, websites, print media, radio, television, and other forms of public communication. Doctors and medical institutions should therefore look at their existing:
- Website content
- Social media profiles and posts
- Videos and educational content
- Advertisements
- Patient-facing promotional material
- Testimonials and endorsements
- Content created or managed by external agencies
The purpose of such a review is not to discourage doctors from communicating with patients. It is to ensure that public communication remains consistent with the professional and ethical standards set out in the guidelines.
2. Distinguish Patient Education From Promotion
Healthcare communication can serve an important public purpose when it provides factual and useful information. At the same time, the guidelines place restrictions on misleading or promotional communication that may create unrealistic expectations about medical services or outcomes. They address issues including false or misleading claims, guarantees of cure, superiority claims, and other forms of promotional communication. This makes the distinction between education and promotion important. A doctor sharing general information about a medical condition is different from presenting a treatment or service in a way that creates an unsupported impression about its outcome. Before publishing content, doctors should therefore consider whether the communication is: factual, transparent and evidence-based or primarily designed to make a promotional claim.
3. Review Testimonials and Patient-Related Content
Patient testimonials, photographs, videos and clinical material can raise particularly sensitive issues. The NMC guidelines specifically address patient privacy and consent, including the use of patient information, photographs, videos, medical records and clinical images for advertising purposes. Doctors and hospitals should therefore review how such material is being used in their communication. A patient's photograph or testimonial should not simply be treated as ordinary marketing content. The relevant question is whether its use is permitted and whether the necessary safeguards and consent requirements have been addressed. For healthcare professionals, protecting patient dignity and privacy should remain central to any public communication involving patient-related material.
4. Review Social Media and Digital Marketing Practices
The guidelines recognise the growing role of digital communication and specifically address social media, online platforms and digital marketing. This is particularly relevant for doctors who have social media teams or engage external marketing agencies. A doctor may not personally create every post appearing on a professional page. However, the communication is still connected with the medical professional or institution. Doctors and healthcare institutions should therefore review the content being created and published on their behalf and ensure that the people handling their communication understand the applicable professional requirements.
5. Pay Attention to Influencers and Endorsements
The guidelines also address endorsements, testimonials, and influencer-related promotional activities. This is an important area for doctors and healthcare institutions using third-party digital personalities to reach audiences. Before entering into such arrangements, the nature of the proposed communication should be carefully considered. The fact that content is being published by an influencer or another third party does not change the professional context in which the healthcare service is being promoted. Doctors and institutions should therefore exercise appropriate caution when using endorsements or third-party promotional arrangements.
6. Review the Use of AI in Healthcare Communication
The guidelines specifically address AI-generated and AI-assisted promotional content. They provide that such content should not create misleading impressions regarding matters such as diagnosis, treatment outcomes, professional qualifications, patient experiences, or healthcare services. The guidelines also address disclosure where the artificial nature of content could materially affect the audience's understanding.
This is particularly relevant as doctors and healthcare institutions increasingly use AI-assisted tools for digital content. AI can assist in preparing communication, but the final content still needs appropriate professional review.
A doctor should therefore ask:
- Is the information accurate?
- Could the content create a misleading impression?
- Does it make an unsupported claim about treatment or outcomes?
- Does it inaccurately represent professional qualifications or patient experience?
- Is disclosure required?
These questions become particularly important where AI-generated content is used for promotional purposes.
7. Check How Fees, Packages and Services Are Presented
The guidelines also address the communication of charges, packages and fees by healthcare institutions. Such communication is expected to remain factual and transparent. Hospitals and clinics should therefore review how fees, treatment packages and related information are presented in advertisements and other public communications. The information communicated to the public should accurately represent what is being offered rather than create an unrealistic expectation. For healthcare institutions, transparency in communication is therefore an important part of responsible public communication.
8. Do Not Treat Marketing Compliance as Only the Marketing Team's Responsibility
One of the practical consequences of these guidelines is that healthcare communication should not be viewed solely as a marketing function. Doctors, hospital management, compliance teams, and external agencies may all be involved in creating or publishing public-facing content. A basic internal review process can help identify potential concerns before content goes live. For example, healthcare institutions can review whether:
- The information is factual and transparent
- Any medical claim is properly supported
- Patient privacy is protected
- Appropriate consent has been addressed
- Testimonials or endorsements are being used appropriately
- AI-generated content has been properly reviewed
- External agencies or influencers are following the applicable requirements
The aim is not to make communication unnecessarily difficult. It is to make responsible communication part of the process.
9. Understand the Consequences of Violations
The guidelines also provide for corrective and disciplinary measures in cases of violations. Depending on the nature and seriousness of the violation, the guidelines provide for measures including warning and mandatory ethics training, censure and monetary penalty, suspension, and, in repeated violations, removal from the register for a specified period. The guidelines also provide an appellate mechanism for an RMP aggrieved by a decision of the State Medical Council. This makes it important for doctors and institutions to take the new framework seriously and review their existing communication practices.
What Should Doctors Do Now?
There does not need to be an immediate move towards stopping digital communication. Instead, doctors and healthcare institutions should consider a structured review of their existing practices. Review. Identify. Correct. Document. Start with existing websites and social media profiles. Examine promotional claims, patient testimonials, clinical images, endorsements and third-party marketing arrangements. Review the use of AI-generated content. Check how fees and services are represented.
Most importantly, ensure that the people responsible for public communication understand the professional standards that apply to medical advertising and communication. The NMC guidelines are intended to ensure that communication involving medical professionals and healthcare institutions remains factual, ethical, transparent and evidence-based, while protecting patients and preserving the dignity of the profession. For doctors, the takeaway is therefore straightforward: Digital visibility should not come at the cost of professional responsibility. Healthcare communication can educate, inform and build trust. But it should do so within the ethical framework governing the medical profession.
Conclusion
The new NMC Guidelines on Ethical Advertising and Public Communication provide a framework for how Registered Medical Practitioners and hospitals or medical institutions should approach public communication. For doctors, this is an appropriate time to look beyond individual social media posts and examine the overall communication practices of their professional practice or institution.
A review of promotional claims, patient-related content, testimonials, endorsements, digital marketing arrangements, AI-assisted content and communication around services and fees can help create a more structured approach to compliance.
The objective should not be to stop doctors from communicating. It should be to ensure that healthcare communication remains responsible, transparent and consistent with professional ethics.
Is Your Medical Practice Ready for the New NMC Guidelines?
If you are a doctor, hospital or medical institution, now is the right time to review your advertising and public communication practices. From social media content and patient testimonials to promotional claims, influencer arrangements and AI-assisted content, compliance concerns can arise across multiple communication channels. Don’t wait for a complaint or regulatory concern to review your practices. Lexcuriam advises healthcare professionals and medical institutions on healthcare law, regulatory compliance and medico-legal risk, helping them assess their practices and navigate the legal framework with greater clarity.
Need help reviewing your healthcare communication practices? Contact Lexcuriam LLP.