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Non-medical home care agency marketing: honest service claims, caregiver stories and review rules

How a private-pay home care agency can market personal care and companion services without implying skilled care, Medicare coverage or fake reviews.

A non-medical home care agency sells help with daily life: bathing, dressing, meals, light housekeeping, errands, transportation and company. Families usually find an agency when something has changed, a fall, a hospital stay, a parent who can no longer manage alone, and they compare two or three agencies quickly. Marketing decides which agencies make that short list, and it also decides whether the first phone call starts with accurate expectations or with a misunderstanding about what the agency does and who pays.

This guide covers the parts of home care marketing that are easy to get wrong: describing non-medical care without sounding like nursing, talking about Medicare and Medicaid, using family and caregiver stories, asking for reviews, paying for referrals, and recruiting caregivers with ads. If your agency is Medicare-certified and provides skilled care, read our guide to home health agency marketing instead; it covers Medicare eligibility and the anti-kickback statute in depth.

This is general information, not legal advice. Sources cited were checked on October 29, 2026: the Medicare.gov coverage pages for long-term care and home health services, 42 U.S.C. 1396n(c), 42 U.S.C. 1320a-7a and 1320a-7b, the OIG Policy Statement Regarding Gifts of Nominal Value (December 7, 2016), 15 U.S.C. 45, 16 CFR 251.1, 16 CFR 255.2 and 255.5, 16 CFR Part 465, 45 CFR 160.103, the Google Business Profile guidelines and the Google Ads personalized advertising policy. Home care licensing differs from state to state; ask a lawyer who knows your state before you rely on any of this.

Say clearly that the care is non-medical

The most common problem in home care marketing is not a dramatic false claim. It is drift. A site starts with companion care, then adds “medication management”, “post-surgical care” and “chronic disease support”, and a family reading it reasonably concludes the agency sends nurses. The FTC Act, 15 U.S.C. 45(a)(1), declares unfair or deceptive acts or practices in or affecting commerce unlawful, and a page that leads families to expect nursing care from a non-medical agency invites exactly that question.

Practical steps that keep the impression accurate:

  • Put “non-medical” in the page title or the first sentence of your services page, not only in a footer.
  • Describe tasks in plain words: help with bathing and dressing, meal preparation, reminders, rides to appointments, company and supervision. These are things a family can picture.
  • Avoid clinical words for non-clinical help. “Medication reminders” and “medication administration” are very different services, and state rules can limit which tasks a non-medical caregiver may do. Use only the wording your license category allows.
  • Do not say or imply that caregivers are nurses, therapists or aides with clinical training unless they are, and unless your license covers that service.
  • If you also run a licensed home health or skilled nursing service, keep it on separate pages with separate calls to action, so a family knows which service they are asking about.
  • Say what you do not do. A short line such as “We do not provide nursing or medical care. If you need skilled care, ask your doctor about home health” saves wasted calls and builds trust.

States differ: a state may license non-medical home care agencies, register them, or have no specific category. Where there is a license, the licensing rules may cover advertising too, for example whether you must show a license number or may use a particular title. Check your state licensing agency before you publish.

Medicare: say what it does not pay for

Many families call a home care agency expecting Medicare to pay. It almost never does for this kind of help, and your marketing should say so plainly rather than leave it to an awkward intake call.

The Medicare.gov page on long-term care describes long-term care, which it also calls custodial care, as including help with personal tasks of everyday life such as dressing, bathing and using the bathroom, and it says that since most long-term care is non-medical, Medicare and most health insurance, including Medigap, do not pay for long-term care services, including care in a nursing home or in the community. The same page says a person may be eligible for long-term care through Medicaid if they meet the requirements in their state, or may buy private long-term care insurance.

The Medicare.gov page on home health services adds that Medicare does not pay for 24-hour care at home, homemaker services unrelated to the care plan, or custodial or personal care when that is the only care the person needs.

So, on your site and in ads:

  • Do not use “Medicare accepted”, “covered by Medicare” or a Medicare logo for private-pay personal care.
  • A short, accurate sentence works: “Medicare does not usually pay for non-medical home care. Families pay privately, and some use long-term care insurance or Medicaid programs where they qualify.”
  • If you mention long-term care insurance, say you can help families check their policy, not that the policy will pay. Coverage depends on the policy.
  • Link to the Medicare.gov long-term care page so families can read it themselves.

Medicaid waiver clients bring federal rules with them

States can pay for personal care at home through Medicaid home and community-based services waivers. Under 42 U.S.C. 1396n(c), a state can, with federal approval, pay for home or community-based services under a written plan of care for people who would otherwise need the level of care of a hospital or nursing facility, and 1396n(c)(4)(B) lists homemaker and home health aide services, personal care services, adult day health services and respite care among the services a waiver may cover.

If your agency also runs a day program, or refers families to one, the payment wording, supervision claims and Medicaid settings rule for day centers are covered in our adult day health center marketing guide.

If your agency is a Medicaid waiver provider, the federal fraud and abuse laws reach your marketing for those clients. If it is purely private pay, the federal anti-kickback statute generally is not the issue, though state law may be. Know which you are before you plan any referral or gift program.

For waiver clients, two federal laws matter most:

  1. The anti-kickback statute, 42 U.S.C. 1320a-7b(b), which makes it a crime to knowingly and willfully offer or pay any remuneration to induce referrals of items or services paid in whole or in part by a federal health care program. Section 1320a-7b(f) defines federal health care program to include state health care programs, which covers Medicaid. Paying a case manager, facility or referral service per Medicaid client is the obvious risk.
  2. The beneficiary inducement law, 42 U.S.C. 1320a-7a(a)(5), which allows civil penalties against anyone who offers or gives a Medicare or Medicaid beneficiary remuneration they know or should know is likely to influence the choice of a provider. OIG has said it reads “nominal value” as no more than $15 per item or $75 per patient per year, and never cash or cash equivalents, in its Policy Statement Regarding Gifts of Nominal Value dated December 7, 2016.

A gift card for signing up, free hours of care for switching agencies, or a cash bonus to a client who refers a neighbor all need review by counsel before you offer them to anyone on Medicaid. Our guides to marketing to Medicare patients and patient and physician referrals cover these rules in more detail.

Free assessments and first visits

“Free in-home assessment” is common home care wording, and it is fine when it is true. The FTC guide on the word “free”, 16 CFR 251.1(c), says the terms, conditions and obligations of a free offer should be set out clearly and conspicuously at the outset, so that a reader is unlikely to miss them. If the assessment is free only when the family books a minimum number of hours, say so next to the word “free”, not in fine print. Our flu shot clinic marketing guide walks through the same rule with example wording.

For Medicaid waiver clients, a free visit or free hours of care is also something of value, so check it against the beneficiary inducement rule above.

Family and caregiver stories

Stories from families are the strongest marketing a home care agency has. They are also endorsements under the FTC Guides Concerning the Use of Endorsements and Testimonials in Advertising, 16 CFR Part 255, and that brings three duties.

  1. The story must be real and current. Do not write a composite family, rename a real one without saying so, or keep a story after the family has asked you to remove it. 16 CFR 465.2 makes it a violation for a business to write or create a consumer testimonial that materially misrepresents that the person exists, that they used the service, or what their experience was.
  2. A key result implies a typical result. Under 16 CFR 255.2(b), a testimonial about a central attribute of a service will likely be read as what customers generally achieve. “Mom was able to stay home for three more years” implies your clients generally can. If you cannot support that, either do not use it or clearly say what families can generally expect.
  3. Disclose connections. 16 CFR 255.5(a) requires clear and conspicuous disclosure of a connection between the endorser and the seller that might materially affect the weight or credibility of the endorsement and that the audience would not expect. A discount, free hours of care, a family relationship with staff, or employment are all examples. 255.5 says material connections can include a business, family or personal relationship, and free or discounted services.

Clients in home care are often older, ill or living with dementia, so permission matters. Get consent in writing from the person in the story, or from the person legally able to give it for them, and keep it. If your agency is a HIPAA covered entity (see below), a story that uses client information for marketing needs a HIPAA authorization; our guide to patient testimonials and before and after photos explains what that form must contain.

Caregiver stories and staff voices

Caregiver profiles and staff videos are good recruiting and good marketing. When a caregiver speaks in an ad aimed at families, the audience may not realize the speaker works for you. 16 CFR 465.5(b) makes it a violation for a business to disseminate a consumer testimonial by one of its officers, managers, employees or agents without clear and conspicuous disclosure of that relationship, when the relationship is not otherwise clear to the audience. A caption such as “Maria, caregiver at our agency” usually solves this.

The same rule reaches reviews. Under 465.5(c), an officer or manager may not ask employees or relatives to post reviews of the business without telling them to disclose their relationship, and must act if such reviews appear without disclosure. The simplest policy is that staff and their families do not review the agency at all.

Reviews: ask everyone, pay no one for praise

Families read reviews closely when choosing someone to come into a parent’s home. The FTC rule on consumer reviews and testimonials, 16 CFR Part 465, was published in 2024 (89 FR 68077, August 22, 2024). The parts that matter most for a home care agency:

  • No buying positive reviews. 465.4 bars giving compensation or other incentives in exchange for, or conditioned on, reviews that express a particular sentiment, positive or negative.
  • No fake reviews. 465.2 covers reviews from people who do not exist, who never used the service, or that misstate their experience, including ones a business buys or posts when it knew or should have known they were false.
  • No hiding bad reviews on your own site. 465.7(b) bars presenting the reviews on your site as most or all of those submitted while suppressing reviews based on their rating or negative sentiment.
  • No fake independent sites. 465.6 bars presenting a site or entity you control, such as a “best home care in your city” page, as an independent source of reviews about your category.
  • No threats. 465.7(a) bars groundless legal threats, intimidation or knowingly false public accusations aimed at getting a review removed or stopping one from being written.

What works is a routine: after the first month of care, and again at a natural point, ask every family the same way whether they would share their experience, with a direct link to your Google Business Profile. Ask every family, not only the happy ones. For replying to reviews, including negative ones that mention a client, see patient review replies.

Referral sources: placement services, facilities and professionals

Home care agencies get many clients from hospital discharge planners, assisted living and senior housing staff, elder law attorneys, care managers and senior placement services. For private-pay clients, the federal anti-kickback statute generally does not apply, but state law can regulate referral fees and placement services, and contracts with placement services often carry their own terms. For any client whose care is paid by Medicaid, the anti-kickback rules described above apply to the referral relationship.

Safer ways to build referral relationships:

  • Give referral sources accurate, printed information about what you do and do not do, your hours, minimum shift length and how fast you can start.
  • Answer and follow up on referrals quickly; speed and reliability are what discharge planners remember.
  • Report back to the referral source when the family agrees, with the family’s permission.
  • Keep a written record of anything of value given to a referral source, and have counsel review any per-referral fee before you sign it.

Our assisted living marketing guide covers the senior housing side of the same relationships.

Does HIPAA apply to a non-medical agency?

Not automatically. Under 45 CFR 160.103, a health care provider is a covered entity only if it transmits health information electronically in connection with a covered transaction, such as billing a health plan. The same section defines health care to include care, services or assessment with respect to a person’s physical or mental condition or functional status. A private-pay agency that bills families directly may not be covered. An agency that bills Medicaid or long-term care insurers electronically may be. Ask counsel which side you are on, because it changes how you can use client information in marketing.

Either way, treat client information as private. Do not post photos of clients in their homes, names, diagnoses or addresses without written consent, and keep tracking pixels off intake forms. If you are a covered entity, read our guides to HIPAA marketing rules and tracking pixels on practice websites.

Recruiting caregivers with ads

Most home care agencies spend as much effort hiring caregivers as finding clients. Job ads are employment ads, and ad platforms limit how they can be targeted. The Google Ads personalized advertising policy says that in the United States and Canada, ads for employment opportunities cannot target by gender, age, parental status, marital status or ZIP code. Plan caregiver campaigns around location radius, job-related keywords and your careers page, not around who you imagine the ideal caregiver to be.

Keep recruiting and client marketing on separate pages and separate campaigns, so job seekers do not land on a page for families and families do not find a hiring ad when they search for care. Our guide to medical practice job ads covers job ad wording, Meta targeting and careers pages in more detail.

Your Google Business Profile

Choose the category that matches the service, describe the care as non-medical in the business description, list the service area truthfully, and use your real-world business name, as Google’s guidelines for representing your business require, without added keywords. Our guide to Google Business Profile for doctors covers the guidelines that apply to health businesses.

Illustration: a services page that gets it right

Illustration. A private-pay agency rewrites its services page. The heading reads “Non-medical home care for adults who want to stay at home”. The first paragraph lists bathing, dressing, meals, medication reminders, rides and company, and says caregivers do not provide nursing or medical care. A short box says that Medicare does not usually pay for this kind of care and links to the Medicare.gov long-term care page. The “free in-home visit” button says, beside it, that the visit is free with no obligation to book. Family stories carry the family’s first name and the person’s written consent on file, and the caregiver video is captioned with each caregiver’s role at the agency. This is an example of structure, not a real agency or result.

Checklist before you publish

  • “Non-medical” appears near the top of every services page and ad landing page.
  • No clinical tasks listed that your license category does not allow.
  • No Medicare coverage claim for personal care; Medicaid and insurance described as “where eligible”.
  • Free offers state their conditions next to the word “free”.
  • Every family story is real, current and consented to in writing; results are typical or the typical result is disclosed.
  • Staff in ads are identified as staff; staff and relatives do not post reviews.
  • Reviews requested from every family; nothing offered in exchange for a positive one.
  • Any gift, free care or fee involving Medicaid clients or their referral sources reviewed by counsel.
  • Caregiver job ads not targeted by age, gender, parental or marital status or ZIP code.

How we help

We build websites, local search, Google Ads and AI front desk tools for independent health and care businesses, and we write and structure pages so the service you actually offer is the one families see. Our lead generation work brings inquiries straight to you; we do not sell or share lead lists. We can set up Google Ads for client and caregiver campaigns separately, and build a website with clear service and careers pages. Our tools are built with HIPAA in mind. We confirm in writing what a BAA covers before any patient information flows through a tool, and if it is not covered, we do not route patient information through it.

Frequently asked questions

Does Medicare pay for non-medical home care?

Generally no. The Medicare.gov long-term care page says Medicare and most health insurance do not pay for long-term care services, which include help with personal tasks such as bathing and dressing. A person may qualify through Medicaid in their state or have long-term care insurance.

Can we say “Medicaid accepted”?

Only if your agency is an enrolled provider for the Medicaid program or waiver you mean, and it helps to add that eligibility is set by the state. If you are private pay only, do not use it.

Can we give a gift card to families who leave a review?

Not one conditioned on a positive review; 16 CFR 465.4 bars that. A small thank you offered to every family for any honest review is a different question, and Medicaid clients bring the beneficiary inducement rule into it, so ask counsel first.

Can our caregivers post reviews of the agency?

It is safest not to. 16 CFR 465.5 requires the relationship to be disclosed, and managers who ask staff to review the agency must tell them to disclose it.

Can we pay a senior placement service a fee per client?

For Medicaid clients, a per-referral fee raises anti-kickback questions under 42 U.S.C. 1320a-7b(b). For private-pay clients, check your state law and the contract terms. Have counsel review any such fee before you sign.

Does HIPAA apply to our agency?

It depends on whether you are a covered entity under 45 CFR 160.103, which turns largely on whether you conduct covered electronic transactions such as billing a health plan. Ask counsel; treat client information as private either way.

Sources

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