How do I market a regenerative service without making a claim?

Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education for licensed providers and is not medical advice. Last updated October 29, 2026.

You market a regenerative medicine service without claims by teaching instead of promising. Say what the service is, how a visit goes, who performs it, what it costs and what its FDA status is. Leave out what it will do for a patient. Then define your terms, answer the questions patients type into their phones, and keep your reviews honest. This post shows how to do each one.

Why are claims the risk in regenerative medicine marketing?

A claim is any line that tells a patient what a service will do for them. So why does that one kind of line matter so much? It matters because of who else reads it.

This is how I say it to providers: “Every time I see someone get a warning letter, the first thing I do is I review it. In most of the letters I read, the company’s own marketing language is part of the evidence.”

Those words sit on a website and in a brochure, where anyone can read them.

I started Regen Portal because doctors kept asking me for consulting and marketing help after their marketing companies let them down. So this post is about a way to market that does not lean on a promise. You teach what the service is, and you let the patient decide.

What counts as a claim on a web page or in an ad?

A claim can be said outright or only hinted at, and the FTC covers both kinds. Its Health Products Compliance Guidance says “a marketer is equally responsible for the accuracy of claims suggested or reasonably implied in advertising.”

How does the FTC decide what an ad implies? It looks at the whole ad at once. The guidance tells marketers to weigh “the ‘net impression’ conveyed by all elements of the ad, including the text, product name, and any charts, graphs, and other images.”

In plain words, a headline, a photo and the name of a package can each carry a claim, even when no sentence on the page makes one. So when you read your own pages, look for these.

• A line that says what the service does to the body or to a condition.
• A named condition set beside the service as the thing it is for.
• A timeline for when a patient will feel or see something.
• A comparison with surgery, a drug or the clinic down the street.
• A comfort word or a risk word, such as “safe,” “painless” or “no downtime.”
• The words “FDA approved” beside a service that is not.
• A photo or a patient quote that tells the same story without the words.

What does the FTC expect before I make a claim?

It expects proof, and it expects you to have the proof first. The guidance opens with two lines. The first is “Advertising must be truthful and not misleading.” The second begins, “Before disseminating an ad, advertisers must have adequate substantiation for all objective product claims.”

Substantiation is a long word for proof. The standard the FTC names is “competent and reliable scientific evidence,” and a happy patient does not meet it. The guidance says “Anecdotal evidence about the individual experiences of consumers” and surveys of those experiences “are never sufficient to substantiate claims about the effects of a health product.”

Now hold that standard up against this field. In its 2026 update, the American College of Rheumatology wrote, “In people with knee and hip OA, we strongly recommend against PRP treatment.” OA is short for osteoarthritis. A practice that wants to promise something about a knee has to answer that sentence first.

That is one source and two joints, and the evidence differs from one use to the next. The lesson for your marketing stays the same, though: if you cannot hand over the evidence for a sentence, do not publish the sentence.

How does my advertising show what a product is intended for?

FDA reads marketing for a different reason than the FTC does. FDA sorts products by what they are intended for, and one place it looks for that intent is the advertising.

The tissue rules say so in the text. Under 21 CFR 1271.10(a), a human cell or tissue product stays under the lighter set of rules only if it meets four tests. The second test is that the product is “intended for homologous use only, as reflected by the labeling, advertising, or other indications of the manufacturer’s objective intent.”

You do not need the full meaning of homologous use for this post. Look at one word in the middle of that sentence, which is advertising. What a company says about a product is part of what shows FDA how the product is meant to be used.

The device rules carry the same idea. 21 CFR 807.97 says a clearance “does not in any way denote official approval of the device.” It goes on: “Any representation that creates an impression of official approval of a device because of complying with the premarket notification regulations is misleading and constitutes misbranding.”

A word of care about these rules. They are written about products and the companies that make and sell them, and how each one reaches a clinic’s own web page is a question for your attorney. I point to them because they show how FDA reads, and FDA reads the advertising.

What does it mean to describe the process, not the promise?

It means your page tells a patient what will happen at the visit, and it stops before it says how things will turn out. A patient can check a process, and you can stand behind every word of it.

Here is what a process page can cover.

• What the service is, in one or two plain sentences.
• How it is prepared and what the visit involves, step by step.
• Who performs it, and what license that person holds.
• What its FDA status is, with the word off-label where it applies.
• What a named source says about the evidence, and where the evidence stops.
• The risks the provider goes over, and the other options a patient has.
• The price, or how a patient gets the price in writing.

Here is an example to adapt. Have your own attorney review your version, and make sure it is true of the system you own.

“PRP stands for platelet-rich plasma. It is prepared in our office from a small sample of your own blood. The system we use is FDA cleared for use with bone graft material, and using PRP by injection is an off-label use. At your visit, the provider goes over the research, the risks, the cost and your other options with you.”

Look at what is missing from that example. It names no condition, it gives no timeline, it compares PRP with nothing, and it says nothing about how a patient will feel.

Let’s say you run a two-provider practice and you are adding PRP. Your web person sends you a draft page. The headline is about what patients will be able to do again, and the photo under it shows a runner on a trail.

What do you do with that draft? You strike the headline, because it promises something, and you take out the photo, because a picture can imply the same thing. Then you write a headline that names the service, and you send the new page to your attorney before it goes live.

How do I define my terms on my site?

You give the terms a page of their own, and you link to it every time one of them shows up. Why bother? A patient cannot weigh a word they do not understand, and a word with a written meaning is harder to stretch into a promise.

A terms page for a practice that offers PRP might define these.

• PRP, or platelet-rich plasma. Our post on what PRP is, in plain terms has a short definition you can adapt.
• Autologous, which simply means the material comes from the patient’s own body.
• Off-label. FDA wrote its definition about drugs: “Unapproved use of an approved drug is often called ‘off-label’ use.” For a cleared device, the idea is a use outside what the device was cleared for.
• Cleared, approved and registered, which are three different words at FDA. Our post on whether PRP is FDA approved walks through them.

Link each definition to the page it comes from, so a patient can read the source for themselves. Then use each word the same way on every page and on the phone.

What questions are patients searching, and how do I answer them?

This is how I explain it: “Let’s say you’re out of town and you’re in the mood for Italian food. What’s the first thing we do? We grab our phones.”

That is how patients look for a provider. They have a question, they pick up the phone, and they type it in. So the plainest marketing you can do is to answer the question they typed.

Where do you find the real questions? You already have them. Ask your front desk to write down what callers ask for a few weeks, and keep your own list of what patients ask in the room.

Your list will be your own, and here is a starter list to check it against.

• What is PRP?
• Is PRP FDA approved?
• What happens at a PRP visit?
• Who does the injection?
• What does it cost, and does insurance pay for it?
• What are the risks?
• What does the research say?

Give each question its own page, and build every page the same way. Answer in the first sentence, then give the source and link to it. Say what is not known. Put a date on the page, with the name of the provider who reviewed it.

Some answers are not yours to give. A coverage question belongs to the patient’s plan, and what your page says about insurance should come from your biller, so say who answers it and stop there.

Will a page like this bring patients in? I can’t promise that, and nobody else can either. What you control is whether the answer on your site is true.

Paid ads sit under platform rules on top of all this, and that subject needs a post of its own.

How do I market PRP when the use is off-label?

You say so, in those words, near the top of the page. A status line in a footer is easy to miss.

Start from what the device is. FDA lists the systems that prepare PRP as a platelet and plasma separator for bone graft handling. In plain words, the devices that prepare PRP are FDA cleared for use with bone graft material. Injecting PRP into joints, tendons, ligaments, skin or scalp is an off-label use.

May a provider use a device off-label? Federal law protects that inside a real provider-patient relationship. The same section of the law adds that it “shall not change any existing prohibition on the promotion of unapproved uses of legally marketed devices.” So using a device and marketing that use are two separate questions.

A PRP page has a few rules of its own.

• Read the 510(k) clearance for the exact system you own, and describe the device the way the clearance does.
• Never write “FDA-approved PRP” or “FDA-approved kit,” because neither phrase is true.
• Never write that PRP is exempt from FDA rules or that it is unregulated.
• If a page names a part of the body, say what a named source reports about it and where the evidence stops.

There is a legal question under all of this. Whether your marketing may name an off-label use at all, and how, is for your attorney to answer, and not for us or for a sales rep.

What do I do about reviews, testimonials and before-and-after photos?

Start with what we do. Regen Med Academy publishes no testimonials and no patient stories.

A testimonial on your own page is a claim you chose to publish. The FTC’s health guidance says, “Testimonials that report results more dramatic than users can generally expect are likely to be deceptive.” A patient story about how things turned out is that kind of claim, and you would need the evidence behind it.

Reviews on outside sites are different, because the patient writes them. The FTC still has rules for how a business handles them. Its rule on consumer reviews and testimonials “went into effect on October 21, 2024,” and its Endorsement Guides questions and answers cover the everyday cases. Here are four plain lines for a practice, each with the FTC’s own words beside it.

• Do not ask for positive reviews. The FTC says “it’s okay to invite all of your customers to post honest reviews, positive or negative.” It adds that asking only the customers you think are happy “would be misleading if it substantially skews the favorability of the reviews.”
• Do not pay for a review or reward one. Asked about paying for 5-star reviews, the FTC answers, “No. That conduct would violate Section 465.4.” Our line is stricter than the rule, and we keep it that way on purpose.
• Do not have staff write them. The FTC tells an employee who reviews an employer’s product, “You definitely should disclose your employment relationship when writing such a review.” For a medical practice, the plain line is that staff do not review the practice.
• Do not hide the negative ones. The FTC says that asking unhappy customers “to change or delete their initial negative reviews could mislead readers.”

Photos work the same way as words, and the FTC’s guidance has an example. An ad pairs a before picture with an after picture, and the guidance says the images and the words beside them “likely convey a claim that the product can dramatically improve the symptoms of arthritis.”

Privacy comes into it too, because HHS says a covered entity “must obtain the individual’s written authorization for any use or disclosure of protected health information that is not for treatment, payment or health care operations or otherwise permitted or required by the Privacy Rule.” Ask your attorney how that applies before a patient’s photo or story goes anywhere public.

Here is our own choice, and it is a choice and not a rule for you. We publish no patient stories on our own site, and for an off-label service we would leave patient stories and before-and-after photos off the pages as well. Your attorney can tell you what the rule is for your practice.

The privacy line is firmer. In a public reply to a review, staff never confirm that someone is a patient, and they never discuss that person’s care.

Which pages does a practice need for compliant regenerative medicine marketing?

No list of pages makes a site compliant. The words on each page do that, and your attorney has the last read. With that said, these are the pages a teaching site is built from.

• One page for each service, built on the process list above.
• A terms page, with each word linked to its source.
• One page for each question your patients ask.
• A page about each provider, with the license they hold and the training they have. A training certificate says a person trained, and it is not a license or a board certification.
• A page that gives the price, or says how a patient gets it in writing, with your payment policy.

Several states with stem cell laws also have their own advertising notices. State law in this field changes, sometimes more than once a year. Our reading of each state, with its sources and the date we checked, is on the rules by state page. It is a starting point, not legal advice.

What does Regen Med Academy’s practice review look at?

A review of your practice is included with our training. It looks at six areas, which are branding, marketing, operations, lead generation, social and strategy. After the review you get a written practice roadmap, and you keep what we find whether you train with us or not.

We also offer a free FDA legal foundations mini course. It is online and self-paced, with five lessons, and it takes about 45 minutes.

Know our limits as well. We are an education company, so we sell education and nothing else. We are not your attorney, we do not give legal advice, and we do not promise that a roadmap will bring you patients.

Frequently asked questions

Does a line such as “results may vary” make a claim okay?

No. The FTC’s health guidance says that “attempts to disclaim dramatic results with statements like ‘Results not typical’ don’t cure the deception.” A disclaimer does not turn a claim you cannot support into one you can. So take the sentence out.

Can I share a study on my website or my social pages?

You can teach from one, with care. Name who did it, where it was published, what was measured and in whom, and link to it so the reader can check. The FTC’s standard is “competent and reliable scientific evidence,” so do not stretch a small study into a promise. Lab or animal data never supports a statement about patients.

Can I market exosomes or other donor products by teaching?

Teaching does not change what a product is. FDA’s consumer alert says, “There are currently no FDA-approved exosome products,” and that such products meant for diseases or conditions in humans “require FDA approval.” So the first question is not about marketing at all. Our post on whether exosome products are legal to use in a clinic covers it.

Who should read my marketing before it goes live?

Two people should read it. The provider whose name is on the service reads every word, and then your own attorney reads it, because how these rules apply to your words is a legal question. After that, pick one person to own the pages, and read what is public again every month.

Will marketing by teaching bring me more patients?

Nobody can promise that, and we will not. A search engine decides what it shows, and a patient decides who to call. What teaching does is make sure that what a patient reads about your service is true and can be checked.

Key takeaways

• A claim is any line, photo or patient quote that tells a patient what a service will do for them.
• The FTC expects proof before a claim runs, and FDA reads advertising as a sign of what a product is intended for.
• Describe the process: what the service is, how the visit goes, who performs it, its status and its price.
• Define your terms on one page, and say off-label in plain words.
• Answer the questions patients type, one page for each, with a source.
• Do not ask for positive reviews, pay for reviews, have staff write them, or hide the negative ones.

RMA disclosure

Regenerative Medicine Academy (RMA) is an education company. We train licensed providers in some of the techniques this post covers. This post is education only. It is not medical, legal, business, tax or financial advice.

How these rules apply to your own pages, ads and reviews is a question for your own attorney.

Your next step

Read your own home page with the list of claim types from this post beside you, and mark every line that promises something. If you want the rules first, get the free FDA course. When you are ready to talk about training and a review of your practice, request a date now. A person reads it and calls you back within one business day.