Neurofeedback and TMS clinic advertising rules: who regulates what you say.

Neurofeedback clinic advertising rules in Ontario depend on who provides the service, because the colleges regulate the clinicians, not the clinic. TMS (transcranial magnetic stimulation) is usually run by physicians under the College of Physicians and Surgeons of Ontario (CPSO). Neurofeedback is often delivered by psychologists or registered psychotherapists, who answer to their own colleges.

The short version: none of these colleges allow testimonials in advertising, clinical claims have to be accurate and backed by evidence, and naming a specific brand of device is restricted for physicians and psychologists. If your website covers more than one profession, write it to the strictest rule that applies.

Who regulates whom

CRPO's rules are covered in detail in our post on marketing a therapy practice within CRPO rules, so this post focuses on the physician and psychology side.

What counts as advertising

The CPSO defines advertising as any communication, paid or unpaid, in print, electronic media, social media or online, made by or on behalf of a physician, whose main purpose is to promote the physician, a service, or a clinic they're associated with. Its advice document lists websites, blogs and social media posts by name.

"On behalf of" matters. CPSO says physicians must make sure ads prepared by a third party comply too, and the psychology regulation makes it misconduct to permit advertising that breaks the rules. So the clinic's website, Google Business Profile and ads are the clinicians' responsibility, even if the owner or a marketer wrote them.

The mixed-team problem

This is the part most clinic websites miss. The CPSO says a physician in a multidisciplinary practice can be associated with the practice's advertising, but the ads must not appear to give the physician's endorsement to services they don't provide, or suggest the physician provides every service offered.

So a page that puts "Dr. Smith, Psychiatry" next to "neurofeedback for ADHD" when a psychologist actually delivers the neurofeedback is a problem. Keep each service page clear about who provides it.

Testimonials and reviews

All three colleges ban testimonials in advertising. The psychology regulation covers testimonials from a client, a former client, or a friend or relative of one. That rules out "patient stories", quoted praise on service pages and reposted thank-you notes.

Online reviews are where it gets subtle. The CPSO says review sites aren't banned, because the public can post their opinions freely. But it says these behaviours could be treated as breaking the testimonial ban:

• Linking to your reviews in your advertising (no "Read our 5-star reviews" button).
• Directing patients to post reviews.
• Posting reviews yourself under other names.
• Paying to remove negative reviews.

The CPSO adds that deleting negative social media comments while keeping positive ones could also be a breach, though removing discriminatory or unprofessional comments is likely fine. CRPO similarly says registrants shouldn't request reviews or promote them.

Replying to reviews

The psychology standards say registrants may not respond publicly to an online review if the reply would let someone identify a current or past client, and must consider possible harm even when they can't be identified. In practice that means short, general replies that don't confirm anyone was a client. Our reputation management for clinics is built around exactly this.

Claims about conditions and outcomes

This is where TMS and neurofeedback marketing most often goes too far. The CPSO policy says physicians must only advertise in a way that's accurate and factual, and, when making statistical, scientific or clinical claims, verifiable and supported by evidence and science. Physicians must not advertise in a way that is:

• False, misleading or deceptive, including by leaving information out.
• Sensationalised, exaggerated or provocative.
• Comparing themselves to other physicians or health professionals.
• Promising or suggesting a better or more effective service than any other physician or health professional.

For psychologists, the regulation bans anything false or misleading and any claim of uniqueness or special advantage that existing scientific evidence can't support. The College's Standards of Professional Conduct 2024 (PDF) add that public information should be accurate and supportable by current professional literature or research.

Words like "cure", "permanent results", "drug-free alternative that works when medication fails" or "the only clinic in Halton that..." are hard to square with those rules. Plain descriptions work better: what the treatment is, who it may be suitable for, what a session involves, and that results vary.

Naming the device

A lot of clinics lead with the brand name of their TMS system or neurofeedback software. Both regulators restrict that.

• CPSO: physicians must not advertise with a reference to a specific drug, appliance or equipment. The advice document says to focus on the service ("I offer this procedure") rather than the brand or trademarked device. Describing the equipment without a brand name may be allowed.
• Psychology: the regulation bans referring to a specific brand of equipment used in your services if it implies you recommend that brand.

So "we offer TMS for depression" is the safer line, not "now offering the [Brand] system".

Before and after images, deals and referrals

The CPSO has strict rules on before and after photos or videos. They must show an outcome that can reasonably and typically be expected, be de-identified unless the patient consented to being identified, and sit next to a statement that results aren't guaranteed.

They also can't be shown to people who didn't go looking, so not in promoted social posts. The CPSO also says ads built on incentives, like contest prizes or gift cards, are less likely to be in good taste.

The CPSO also bars physicians from schemes where someone else steers patients to them, and gives group discount companies and referral kickbacks as examples. The psychology regulation treats soliciting potential clients directly as misconduct.

Titles and "specialist"

For physicians, the CPSO says a name in advertising must be followed by their certified specialty (or "General Practitioner"), and any focus area must start with "practising in".

The psychology standards say that because the College doesn't issue specialist designations, registrants can't claim to be specialists, but they can describe the focus of their practice. Psychologists must also use the title the College granted them.

What works within the rules

None of this stops a clinic from being found. It just changes what does the work.

• Service pages that explain, not promise. What TMS or neurofeedback is, how assessment works, how many sessions are typical, and who provides it. This is the core of good neurofeedback clinic marketing and of our psychiatry and TMS clinic SEO.
• Accurate clinician bios with the right title and college for each person.
• Clear referral and intake info. Whether a referral is needed, fees, and what happens at the first visit.
• A complete Google Business Profile with services listed plainly and no review requests.
• A fast, accessible site that's easy to use on a phone. Our health clinic websites are built this way.

A quick audit of your clinic's advertising

• No testimonials, patient stories or quoted praise anywhere
• No review requests, review links or rating widgets in your ads or on your site
• No "cure", "guaranteed", "best" or "only clinic" wording
• Every clinical claim backed by evidence you could point to
• No device or software brand names used to promote the service
• Each service page says which profession provides it
• Physicians listed with their specialty, psychologists with their College title
• No discount deals or referral payments
• Review replies never confirm someone was a client