April 12, 2023. This article was updated to reflect additional policy changes and restrictions for Australian medical aesthetic practitioners.
If you are a plastic surgeon or aesthetic practice located in Australia, you may be faced with new guidelines and restrictions that will have considerable implications for your entire digital marketing program.
You should be aware of each of these new guidelines in order to remain compliant with all legal advertising policies in the future, and, equally as important, know how your current digital marketing assets must change to remain in compliance moving forward.
The proposed policies would eliminate many of the aesthetic industry’s digital marketing staples for plastic surgeons. Stock imagery, influencers, colloquial language — even the use of emojis — are all on the table to be reviewed and potentially banned, among others.
It is important to note that the changes come from an initiative started in November of 2021, which began an independent review of not only advertising practices but also the education and training of medical staff, the validity of current qualifications, and general medical communication.
What Are the Proposed Changes?
Cosmetic Surgery Requires GP Referral
New Policy Language: Under the reforms, patients seeking cosmetic surgery will need a referral from their GP.
What Does This Mean for My Practice? Under this new requirement, any patient seeking cosmetic surgery will first need a referral from their general practitioner. You should start developing relationships with local GPs or create easy-to-fill-out forms for patients to take to their GPs. It may still be possible to schedule consultations with patients before having referrals. At which point, you can better educate the patient on precisely what they are requesting a referral for. This means your usual patient funnel might not change — just a bit of the process between consultation and procedure.
Why Is This Being Enacted? Here is the language provided by Ahpra: This new measure adds a layer of protection for patients, who will in future be able to discuss their motivation for cosmetic surgery with their GP who has the best knowledge of their medical history and can share this with the doctor being referred to.
Cosmetic Surgery Advertisements Must Be Labeled as Adult Content
New Policy Language: Cosmetic surgery advertising must be identified as adult content.
What Does This Mean for My Practice? If your practice is participating in social media advertising, you must make sure that you toggle the adult content option to stay compliant with this change. This will likely not change much about your process since anything under the health umbrella is already technically labeled as “adult content” by platforms. Banner ads, or advertisements listed on other websites, are different, and will require more manual review to stay compliant.
Why Is This Being Enacted? Here is the language provided by Ahpra: The new Medical Board guidelines, combined with the use of software to proactively monitor advertising, are significant steps towards increasing patient safety, protecting the public and putting Australia on a path to being a leading country in regulating the cosmetic surgery sector.
More Scrutinous Patient Assessments
New Policy Language: Other changes in the revised and strengthened Guidelines for registered medical practitioners who perform cosmetic surgery and procedures include … improved patient assessment by practitioners before surgery, including more scrutiny for signs of body dysmorphic disorder.
What Does This Mean for My Practice? This should not change much about your usual operations, assuming you already have implemented an effective patient assessment process. You can review the new guidelines to see what areas of your intake and assessment need expansion.
Why Is This Being Enacted? Here is the language provided by Ahpra: This new measure adds a layer of protection for patients, who will in future be able to discuss their motivation for cosmetic surgery with their GP who has the best knowledge of their medical history and can share this with the doctor being referred to.
No Influencer Marketing
Proposed Policy Language: Responsible advertising of cosmetic surgery must not use paid social media ‘influencers’, ‘ambassadors’ or similar, as this increases the risk that patients are not fully informed and form unrealistic expectations of results.
What Does This Mean for My Practice? Under the new guidelines, no person would be allowed to receive compensation for the promotion of cosmetic surgery, including monetary or otherwise. All influencer marketing in progress and planning must be stopped. You may need to prepare to remove any residual influencer marketing content on your channels.
Why Is This Being Recommended? Excerpt from the Review: “Research suggests a connection between social media use and the increasing incidence of body dysmorphia and other body image concerns (particularly among young women). In these circumstances, the review is particularly concerned with tactics employed by some practitioners, particularly on social media, including […] the use of influencers to promote procedures.”
No More Emoji Use
Proposed Policy Language: Advertising must not trivialise cosmetic surgery. Advertising must not […] c. use emojis
What Does This Mean for My Practice? You may need to prepare your marketing and communications teams for this change, including potentially revising current and past marketing materials to no longer include the use of emojis. This includes all platforms, such as social media, email, website, blogs, video production, etc. You will need to find alternative ways to communicate feelings and ideas traditionally represented through emoji use.
Why Is This Being Recommended? Although the initial review did not make this explicit recommendation, the proposed documents being considered as of now include very clear language that they would not be allowed. For context, the initial review did, however, include the following statement from one health practitioner, “[…] the use of filters, emojis and other forms of photo or video editing should be restricted on posts relating to cosmetic surgery, as this trivialises the procedures, minimises the risks, and exaggerates the benefits […]”
No Surgical Videos for Entertainment
@therealtiktokdoc Reply to @busgirl90 #bownsanatomy #learnontiktok #plasticsurgery #tummytuck
Proposed Policy Language: Any video content in advertising should be used responsibly, for information and/or education only. Videos of patients and surgical procedures must not be presented for entertainment.
What Does This Mean for My Practice? If you are currently sharing videos featuring surgical procedures on platforms like TikTok, YouTube or Instagram, these videos must take an educational perspective and no longer be posted simply for entertainment value. Achieve this by adding informative context to your videos, e.g. process explanations, procedure choice specifics, incision locations rationale, etc.
Why Is This Being Recommended? Excerpt from the Review: “[…] academic literature and previous reviews have identified the potential for cosmetic surgery advertising to mislead, noting that its primary intention is to sell, not educate. Submissions to this review have been highly critical of the advertising approach of some practitioners in this space and have called for Ahpra and the Medical Board to do more. Consumer research undertaken as part of this review highlights the potential reach and influence of advertising in this sector and on the ability of consumers to make informed choices.”
No Single Photo Imagery
Recommendation Language: Use of single images alone, rather than ‘before’ and ‘after’ photographs can idealise cosmetic surgery and must not be used as they can mislead and increase unreasonable expectations of beneficial treatment. This includes the use of stock images, models and celebrities or re-posting a patient’s social media image.
What Does This Mean for My Practice? It is likely that you will need to plan ahead for all of your content sharing platforms to ensure that you have both before and after photos of everyone you want to feature. While seemingly cumbersome, this method of advertising was already considered best practice by savvy marketers since it provided the most convincing and authentic experience for the consumer.
Why Is This Being Recommended? Excerpt from Ahpra document: “Health care advertising that is ethical and responsible helps to keep people safe by providing them with accurate and balanced information that can be used to make informed decisions about cosmetic surgery.”
No Stock Imagery or Models
Recommendation Language: avoiding the use of images of models who have not undergone a cosmetic procedure(s) to promote a cosmetic procedure
What Does This Mean for My Practice? It will no longer be acceptable to use stock imagery of people who have not undergone treatment in your digital marketing program. At this point, we are unsure of whether this includes website designs, but you can be confident that stock imagery in social media, advertisements, email, etc. will no longer be acceptable. One remedy is to be more cognizant of creating a strong before and after image program with high quality stills for use.
Why Is This Being Recommended? Excerpt from the Review: “[…] the review is particularly concerned with tactics employed by some practitioners, particularly on social media, including using images of models who are unlikely to have had cosmetic surgery to promote a particular surgical procedure…”
No Ambiguity About Qualifications
Recommendation Language: Excerpt from the Review: “1. The Medical Board seek to establish an area of practice endorsement for cosmetic surgery; 2. If an area of practice endorsement is approved for cosmetic surgery, Ahpra and the Medical Board, in consultation with other stakeholders, undertake a public education campaign to assist consumers to understand the significance of an endorsement.”
What Does This Mean for My Practice? You will need to be crystal clear about your qualifications; this means no longer using generic phrasing like “board-certified.” Instead, offer the audience the full title of the qualification, where it was attained from and any other relevant information. You may need to prepare to comply with new qualification standards set by Ahpra or other organizations.
Why Is This Being Recommended? Excerpt from the Review: “There is a lack of objective and unbiased information about the training and qualifications of practitioners in this sector, and cosmetic surgery lacks the protective measures found in other parts of the health system that inform consumers and direct them to qualified practitioners.”
No Implications That Surgery Is “Needed”
Recommendation Language: avoiding the use of content that implies cosmetic surgery should be utilised to obtain an acceptable/ideal body type
What Does This Mean for My Practice? In all of your marketing material — web copy, social media, email, ads, etc. — you will have to avoid making claims such as, “if you find yourself with unwanted belly tissue, a tummy tuck may be needed.” Instead, ensure substitute language is used, such as “a tummy tuck may help reduce any unwanted excess skin around your abdomen.” The goal of this shift is to make sure that you are not personally implying an issue with the patient’s existing appearance.
Why Is This Being Recommended? Excerpt from the Review: “In these circumstances, the review is particularly concerned with tactics employed by some practitioners, particularly on social media, including […] content that actively encourages people to pursue what is promoted as a socially accepted or perfect body type […]”
No Colloquialisms Like “Summer” or “Bikini” Body
Recommendation Language: avoiding the use of content that implies cosmetic surgery should be utilised to obtain an acceptable/ideal body type
What Does This Mean for My Practice? You will no longer be able to use the colloquialisms in your marketing program, most notably in social media, where hashtags that fall into these categories are abundant. You will also need to take care to avoid using them in email subject lines, blog titles, or other general marketing copy.
Why Is This Being Recommended? Operation Redress, a research and advocacy group, was quoted in the review with the following: “Too many providers are using hashtags and captions such as #bodygoals, #curveinspo, #bikinibody, #bodyinspo and #summerbody to promote cosmetic surgery. The idea that some human bodies are not Summer-ready for aesthetic reasons is surely not supported by acceptable evidence. Doctors, who are esteemed people in society should not, in our view, be perpetuating the myth that you must look a certain way or be a certain size in order to wear a bikini, or be allowed to enjoy the Summer.”
No Referencing Psychological Benefits
Recommendation Language: limiting benefit statements to those that are objectively demonstrable/provable (that is, the physical changes – not claimed psychological or social benefit)
What Does This Mean for My Practice? Phrases like “a facelift can help you improve your self-esteem and make you feel great about yourself” would be banned since they do not focus on the tangible physical benefits of the procedure but rather on the potential psychological benefits that the review believes are not based solidly on medical research.
Why Is This Being Recommended? Excerpt from the Review: “Research suggests that generally cosmetic surgery does result in patients having increased satisfaction with their appearance. However, the research is mixed about whether cosmetic surgery improves self-esteem. Some studies suggest a small increase in self-esteem, while other studies find no significant changes in self-esteem, and note conflicting results in other studies. As has been noted elsewhere in this report, consumers with body dysmorphic disorder (BDD) are very unlikely to experience improved self-esteem from these procedures.
General Tips for Remaining Compliant
- Provide only realistic, unaltered, integral before and after photos in your marketing program. Make sure all photos are taken from the same angle, with similar lighting, matching all other conditions as much as possible. If anything may appear as though it skews the results, avoid it at all costs.
- Be transparent about result variance. As a general rule of thumb, the new policies are aimed at providing a balanced view of both good and bad outcomes from cosmetic procedures. While it is not necessary to focus on bad or neutral outcomes, it is important to inform the patient that results can vary, depending on their unique conditions and reaction to treatment.
- Avoid referencing cosmetic conditions as problems. Instead, acknowledge that they are a natural part of life that everyone experiences to different degrees. Emphasize that all bodies are normal and natural, regardless of weight gain, aging or other factors. Place focus on whether the patient prefers this part of their body, and offer a solution for them if it is simply not their preference.
- Do not omit unflattering information from your marketing material. You should never omit information because it might dissuade someone from having a treatment performed. Be honest about the recovery and results, the severity of pain and discomfort, the potential for issues to arise, and other information that the patient would want to be privy to.
How to Thrive In the New Ecosystem
The best way to thrive in the wake of these stricter policies is to enforce even stricter regulations on yourself. Long before these recommendations were drafted, digital marketing had already begun to circle toward a more transparent and authentic dynamic between marketers and patients.
Search engines like Google have implemented concepts like E-A-T, which focus on expertise, authoritativeness and trustworthiness to dictate the rankings of search results.
But equally as impactful is the mindset of the consumer in the cosmetic medicine industry, in which the importance of presenting an authentic persona and building meaningful relationships has become omnipresent.
Social media marketers that provide the most personalized and personable experiences are the ones that typically get the most attention.
Content that speaks to a potential patient’s direct concerns and gives them something to relate to performs much higher than generic copy.
Advertisements that leverage an understanding of their audience have higher conversion rates and ROIs.
In short, if you are thinking about how you can perform the least amount of effort to remain compliant with these changes, and not thinking instead about how you can better align with today’s more critical and savvy cosmetic consumer, you are setting yourself up to barely survive, not thrive in the new consumer market.
There is no better time than now for cosmetic surgeons or medical professionals in Australia to consider a full or soft rebrand to better align with the direction consumers and governing agencies are moving toward, especially if you were already falling behind on the current legislation.
Proposed Ahpra Policies: Link
Need More Information on Navigating These Changes?
These proposed regulatory changes are just the tip of the iceberg. There are a lot more potential shifts on the horizon, which means even more work that you will need to do to stay in line with regulations.
Don’t feel overwhelmed. If you need some help, our educators are here to answer any questions you have, anytime, for free. Give us a call at (800) 949-0133 or schedule a one-on-one.
Christian Shepherd
Content Stategist
Incredible Marketing
