What State Boards and Google Actually Require for Treatment Center Advertising — and What Gets Centers Shut Down

Treatment center marketing operates under three overlapping regulatory layers, each with distinct enforcement mechanisms. Understanding where these layers intersect prevents the compliance gaps that trigger investigations.

Layer 1: Federal regulations include FTC truth-in-advertising requirements, SAMHSA treatment outcome guidelines, and 42 CFR Part 2 patient confidentiality rules. The FTC's Health Products Compliance Guidance applies directly to treatment outcome claims — that '85% success rate' on your homepage is an FTC matter.

Layer 2: State licensing and advertising laws vary dramatically. Florida's approach differs fundamentally from California's, which differs from Texas's. A compliant campaign in one state may violate regulations in another where you accept patients from.

Layer 3: Platform policies — primarily Google's LegitScript requirement — add another compliance gate. Google suspended treatment center advertising entirely in 2018, then reopened it only for LegitScript-certified facilities.

Note: This is educational content, not legal advice. Regulations change, and enforcement varies by jurisdiction. Verify current requirements with your licensing authority and legal counsel before implementing marketing strategies.

What makes treatment advertising uniquely complex is that these layers interact. A Google Ads violation may trigger LegitScript review. A state investigation may surface FTC concerns. A patient complaint about marketing claims may escalate to licensing board review. Compliance requires addressing all three layers simultaneously.

State regulations represent the most variable — and often strictest — compliance layer. These examples illustrate the range of requirements, though this is not exhaustive.

Florida enforces some of the nation's strictest treatment advertising rules following the 'Florida Shuffle' crisis. The Patient Brokering Act (§817.505) criminalizes paying for patient referrals, with penalties including felony charges. The state also requires specific license number disclosures in advertising and restricts certain outcome claims.

California regulates treatment advertising through the Board of Behavioral Sciences (BBS) and Department of Health Care Services (DHCS). Facilities must accurately represent licensure status, and there are restrictions on how facilities advertise relationships with licensed professionals.

Texas requires treatment facilities to include specific disclosures about services offered and operates under Health and Safety Code Chapter 464 advertising provisions.

New Jersey added Consumer Fraud Act provisions specifically targeting treatment center advertising after high-profile cases of misleading marketing claims.

• License number display requirements (varies by state)
• Referral payment prohibitions (strictness varies)
• Required disclosures about accreditation or certification
• Restrictions on testimonials and success rate claims
• Multi-state advertising considerations when accepting out-of-state patients

As of 2024 — verify current rules with your state licensing authority, as enforcement priorities and specific requirements change.

Google suspended all addiction treatment advertising in September 2018 following investigative reporting about fraudulent treatment centers. When Google reopened treatment ads in 2019, it required LegitScript certification as a prerequisite.

What LegitScript certification requires: LegitScript reviews facilities for state licensing compliance, HIPAA policies, clinical protocols, and marketing practices. The certification process involves documentation submission, potential site visits, and ongoing monitoring. Certification typically takes several weeks and requires annual renewal.

What triggers LegitScript review: Beyond initial certification, LegitScript conducts ongoing monitoring. Patient complaints, state enforcement actions, or marketing practice changes can trigger re-review. Loss of LegitScript certification means immediate Google Ads suspension.

The organic SEO distinction: LegitScript certification is required for Google Ads, not organic search rankings. You can rank organically without LegitScript certification. However, the marketing practices that would cause LegitScript certification denial — misleading claims, unlicensed operations, referral kickbacks — would likely violate FTC and state rules that apply to all marketing, including SEO content.

Practical implication: Many treatment centers pursue LegitScript certification even if focused on organic SEO because the certification process forces documentation of compliant marketing practices. It's also a trust signal for potential patients and referral sources researching your facility.

Outcome claims represent the highest-risk area of treatment marketing. SAMHSA guidelines, FTC requirements, and state regulations all restrict how facilities can discuss treatment effectiveness.

Claims that typically violate regulations:

• 'Cure' language — addiction is medically recognized as a chronic condition
• Specific success rate percentages without rigorous methodology disclosure
• Guarantees of sobriety or recovery outcomes
• Comparisons claiming superiority over other treatment approaches without substantiation
• Testimonials presented as typical outcomes without appropriate disclaimers

Claims that are generally permissible (with appropriate framing):

• Evidence-based treatment modalities used (MAT, CBT, DBT)
• Accreditation and licensing credentials
• Staff qualifications and certifications
• Amenities and program structure descriptions
• Patient testimonials with clear 'results not typical' disclosures

The testimonial disclosure requirement: FTC's Endorsement Guides require that testimonials reflect typical results, or include clear disclosure that they don't. 'Results may vary' is generally insufficient — the FTC expects disclosure of what results are typical.

This guidance reflects general FTC and SAMHSA principles. Specific requirements vary by state, and enforcement interpretation evolves. Review claims with legal counsel before publication.

Understanding how violations typically surface helps prioritize compliance efforts. Based on industry enforcement patterns, these scenarios represent common pathways to investigation.

Scenario 1: Competitor complaint — A competing facility files a complaint with the state licensing board about claims on your website. The board investigates, discovers additional issues, and initiates enforcement action. This is common in competitive markets where facilities actively monitor competitor marketing.

Scenario 2: Patient or family complaint — A former patient or family member feels misled by marketing claims that didn't match their treatment experience. They file complaints with the state board, FTC, or both. One complaint rarely triggers major enforcement, but patterns of complaints do.

Scenario 3: Google Ads audit — Google or LegitScript reviews your ads and finds claims inconsistent with certification requirements. Your ads are suspended pending review. If resolution isn't quick, you lose a patient acquisition channel while competitors continue advertising.

Scenario 4: Investigative journalism — Media investigations into treatment industry practices surface your facility. Even if you're not the focus, being mentioned in investigative coverage triggers regulatory scrutiny and referral source concern.

Scenario 5: Referral kickback investigation — A referral partner is investigated for Patient Brokering Act violations. Your facility's relationship with them surfaces in the investigation, expanding enforcement scope to your operations.

The common thread: violations rarely surface through random audit. They surface through complaints, competitive pressure, or adjacent investigations. Compliance is risk mitigation against these specific pathways.

A common misconception: advertising regulations only apply to paid ads. In reality, FTC and state rules apply to all commercial marketing communications, including organic website content, blog posts, and social media.

Website content under FTC jurisdiction: Your service pages, treatment descriptions, and outcome claims fall under FTC truth-in-advertising requirements. A misleading success rate claim on your website is just as much an FTC matter as the same claim in a Google Ad.

SEO content that triggers compliance review:

• Treatment outcome statistics without methodology disclosure
• Testimonial pages without appropriate disclaimers
• Comparison content claiming superiority without substantiation
• Local SEO content with license number omissions (where required by state)
• Blog content making clinical claims without appropriate expertise attribution

The E-E-A-T connection: Google's quality guidelines emphasize Experience, Expertise, Authoritativeness, and Trustworthiness for YMYL (Your Money or Your Life) content. Healthcare is explicitly YMYL. Compliant content — accurate, appropriately disclaimed, expert-attributed — aligns with what Google's quality evaluators look for. Non-compliant content often fails E-E-A-T standards independently of regulatory concerns.

For treatment center SEO specifically, compliance isn't separate from optimization strategy. Content that regulators would flag often performs poorly in Google's quality evaluation as well. Building regulation-compliant SEO for rehab centers addresses both concerns simultaneously.