Advertising cash prices: offers and Google Ads

More practices now publish cash prices: a self-pay visit fee, a price for a common procedure, a package of sessions, a membership. Patients search for them, and a clear price on a page can answer the question that otherwise keeps someone from booking. Price advertising also comes with old, specific federal guidance that most marketing checklists skip.

This guide covers how to advertise cash and self-pay prices for a practice: the FTC guides on bait advertising and on the word “free”, how to handle starting-at prices and packages, and the Google Ads rules that apply when a price appears in an ad. It is written for independent practices, including dental, med spa, chiropractic, integrative and primary care. Before you offer a military or veteran discount, read our guide to marketing to veterans and military families. For teacher, first responder and healthcare worker discounts, see occupational group discounts. For deadlines, countdown timers and seasonal sales, see holiday and limited-time procedure sales. If a price ad mentions health accounts, see HSA and FSA eligible claims in practice ads. If prices also appear in a calculator on your site, see cost estimator tools on a practice website. Refund and forfeiture terms for deposits on advertised procedures are covered in our guide to booking deposits and cancellation fees. Listing your prices on a third-party site is covered in listing a practice on price comparison and booking marketplaces. If a price ad carries a refund promise, see our guide to money-back guarantees in healthcare ads. Practices that promote prescription discount cards should read prescription discount card marketing.

This is general information, not legal or medical advice. Sources cited were checked on October 29, 2026: Section 5 of the FTC Act (15 U.S.C. 45), 45 CFR 149.610 (good faith estimates for uninsured or self-pay individuals), 45 CFR 180.10 (hospital price transparency scope), the FTC Guides Against Bait Advertising (16 CFR Part 238), the FTC Guide Concerning Use of the Word “Free” (16 CFR 251.1), the FTC Guides Against Deceptive Pricing (16 CFR 233.1), and the Google Ads policy pages on Misrepresentation, Price asset requirements and Promotion asset requirements. State laws and professional board rules on fee advertising differ and are not covered here. Have a health care attorney review your price advertising before it runs.

The legal baseline: no deceptive price claims

Section 5 of the FTC Act, 15 U.S.C. 45, declares unfair or deceptive acts or practices in or affecting commerce unlawful. A price in an ad is a claim like any other: it has to be true, and the impression it leaves has to be true. The FTC has also published guides that apply this general rule to specific kinds of price advertising. Three of them matter most for practices: the bait advertising guides, the guide on “free” offers, and the deceptive pricing guides.

These guides are not separate statutes. They explain how the FTC views certain practices under Section 5. That is useful for a practice, because they read almost like a checklist of what not to do.

Bait advertising: the price has to be a real offer

Under 16 CFR 238.0, bait advertising is “an alluring but insincere offer to sell a product or service which the advertiser in truth does not intend or want to sell.” The same section says its purpose is to switch people to something else, usually at a higher price, and that its primary aim is “to obtain leads.” The definition of advertising there includes any form of public notice, so it covers your website, social posts, ads and email.

That last point is why the guide fits practice marketing so closely. A low advertised price that is mainly there to get people on the phone, after which staff steer most of them to a different and more expensive service, is the pattern the guide describes.

16 CFR 238.3 lists acts the FTC considers when deciding whether an offer is genuine. Translated to a practice setting, the ones to watch are:

Refusing to provide the advertised service on the advertised terms.
Running down the advertised service to the patient, for example telling most callers it “rarely works” and that they need the premium option instead.
Not having enough appointments to meet reasonably expected demand, unless the ad clearly says availability is limited.
Paying or penalizing staff in a way designed to keep them from selling the advertised service.

16 CFR 238.2(b) adds that the law is violated if the first contact is secured by deception, even if the true facts come out later. Explaining the real price on the phone does not fix an ad that was misleading.

16 CFR 238.4 covers “switch after sale”: accepting a deposit for the advertised item and then switching the buyer to a higher priced one, or failing to deliver or refund within a reasonable time. For a practice that takes a deposit for a package or a procedure, that is a reason to have a written refund policy and to follow it. Our guide to bait and switch in healthcare ads covers the rest of part 238, including staff scripts and pay plans.

None of this means a clinician cannot recommend a different service after an exam. Clinical judgment comes first. The question the guide asks is whether the advertised offer was a bona fide effort to sell what was advertised.

Starting-at prices, ranges and packages

The most common cash price formats in practice marketing are a starting-at price, a range, a per-unit or per-session price, and a package. Each can be honest. Each can also leave a misleading impression if the conditions sit somewhere the patient will not see them.

Starting-at prices. A starting-at price implies that some real patients pay that price. If almost nobody qualifies for it, the format works like bait. Put the main reason the price goes up next to the price, not only on a separate fee page.
Ranges. A range is often more honest than a single number for services that depend on an exam. Say what moves a patient up or down the range.
Per-unit and per-session prices. Say what a unit or session is, and whether a typical course involves more than one.
Packages. List what is included and what is not, such as a consultation, follow-up visits, lab work or supplies, and whether unused sessions are refunded.
Required extras. If a consultation or exam fee is required before the advertised service, say so with the price.

Illustration only, with no real prices: an ad that says “Visits from $[price]” while the page explains that the price applies to an established patient visit and that a first visit costs more, is clearer when the first visit price sits on the same line. Putting the condition in the same place as the number is the habit that matters.

Google states the same idea in its Misrepresentation policy. Under “Dishonest pricing practices” it does not allow a “failure to clearly and conspicuously disclose the payment model or full expense that a user will bear before and after purchase,” or pricing practices “that create a false or misleading impression of the cost of a product or service.”

Free offers: what the FTC guide expects

A free consultation or a free add-on with a paid service is one of the most common offers in self-pay marketing. The FTC guide on the word “free”, 16 CFR 251.1, sets out several expectations:

When something is free with a purchase, the patient should pay no more than the regular price for the paid service. The practice should not recover the cost by raising that price or cutting the quality of the service (251.1(b)(1)).
“Regular price” means the price at which the service was openly and actively sold for a reasonably substantial period, which the guide describes as a 30 day period (251.1(b)(2)).
All terms and conditions should appear clearly and conspicuously at the outset of the offer, in close conjunction with it, not in a footnote reached through an asterisk (251.1(c)).
A single kind of service should not be advertised with a free offer in a trade area for more than 6 months in any 12 month period, and no more than three such offers should be made in the same area in a 12 month period (251.1(h)).
Calling the item a “gift”, “bonus” or “given without charge” does not fix an offer that fails these tests (251.1(i)).

The guide also says that if a service is usually sold at a negotiated price rather than a regular price, it is improper to offer something free with it (251.1(g)). A practice that sets prices case by case should think twice before running a free add-on offer.

Free offers raise a separate federal issue when the patient has Medicare or Medicaid. That is covered in our guides to marketing to Medicare patients and chiropractic new patient offers.

Discounts and “was” prices

A discount ad compares a price to something: a former price, a regular price or a competitor’s price. Under 16 CFR 233.1, a comparison to your own former price is legitimate if the former price was the actual, bona fide price at which the service was offered to the public on a regular basis for a reasonably substantial period of time. A price raised briefly so it can be cut later is the fictitious former price the guide describes. Our guide to was/now and sale price claims covers former, value and suggested retail price comparisons in detail.

In practice that means keeping a record of when each listed price was in effect. If you run a seasonal discount, the regular price should be the one patients actually paid before it. Our guide to dental membership plan advertising covers savings claims for membership plans in more detail.

Prices in Google Ads

Google Ads has its own rules on prices, on top of the general advertising law. The ones most likely to affect a practice are these.

Unavailable offers. Google’s Misrepresentation policy does not allow “promising products, services, or promotional offers in the ad that are unavailable or aren’t easily found from the destination.” If the ad names a price, the landing page should show the same price for the same service.
Price assets. Price assets show a list of services with prices under an ad. Under Google’s Price asset requirements, price information and promotional text such as “Sale” are not allowed in the header or description fields, and the asset URLs must lead to the same final URL domain as the ad.
Promotion assets. Promotion assets show a sale or deal. Google lists Unavailable offers among the policies most relevant to them and says products or services should be priced accurately, easily found at the ad’s destination, and match the headers and descriptions.
Healthcare content. A price ad for a regulated service is still a healthcare ad. Treatments and claims fall under Google’s Healthcare and medicines policy whatever the price.

A simple control works well here: every price that appears in an ad, asset or promotion has a matching line on a single public price page, and the price page is the only place prices are edited. When a price changes, the ads are updated from that page.

A practice owned by a hospital and run as a hospital outpatient department has an extra price issue: Medicare patients can owe a hospital facility charge as well as the clinician’s charge. A price claim that leaves it out can mislead. See our guide to facility fee disclosure.

Prices, estimates and transparency rules are separate

Advertising a cash price does not replace other price rules. 45 CFR 149.610 sets separate requirements for giving uninsured (or self-pay) individuals a good faith estimate of expected charges, explained in our guide to good faith estimates for self-pay patients. The advertised price and the estimate should tell the same story.

Hospitals have their own rules: 45 CFR Part 180 requires each hospital operating in the United States to make public its standard charges. It is a hospital rule; see hospital price transparency requirements. Practices that sell memberships should also read our guide to concierge medicine marketing, and practices that advertise payment plans should read advertising patient financing. A walk-in clinic that posts a price menu inside a store should also read retail health clinic marketing.

A short checklist before a price goes live

The price is one you will actually provide, to the patients the ad reaches, with appointments available.
Conditions that change the price sit next to the price.
Required extras, such as a consultation or exam fee, are stated with the price.
Any “free” item is truly free, with no markup on the paid service, and its terms appear with the offer.
Any “was” price is a real former price with a record of when it applied.
The ad, any price or promotion asset, and the landing page show the same price.
Staff and any phone or chat assistant know the advertised offer and do not discourage it.
The good faith estimate for the same service matches the advertised price, or the difference is explained.
Offers aimed at people who may have Medicare or Medicaid have been reviewed separately.

California, Minnesota and Virginia, for example, now require advertised prices to include each mandatory fee. See our guide to state all-in pricing laws for practices.

How we approach price advertising

When we run Google Ads for practices, prices in ads come from the practice’s own published price page, and ad copy is checked against it before launch. Our healthcare landing pages guide covers how to place price conditions so patients see them. We do not write claims about results, and we do not run offers we have not seen in writing.

Can a medical practice advertise its prices?

Generally yes. Federal law does not ban truthful price advertising. Section 5 of the FTC Act prohibits deceptive practices, so the price and the impression it leaves must be accurate. State law and professional board rules can add requirements, so check them for your state and profession.

What is bait advertising?

Under 16 CFR 238.0, it is an alluring but insincere offer to sell something the advertiser does not intend or want to sell, used to switch people to something else, usually at a higher price, and to obtain leads.

Is a starting-at price allowed?

It can be, if real patients pay that price and the main conditions that raise it appear next to it. A starting-at price that almost nobody qualifies for can create a misleading impression.

How often can we run a free consultation offer?

16 CFR 251.1(h) says a single kind of service should not be advertised with a free offer in a trade area for more than 6 months in any 12 month period, with no more than three such offers in that period. Free offers to Medicare or Medicaid patients raise separate federal issues.

Can we put prices in a Google Ads price asset?

Yes, in the price fields. Google’s Price asset requirements do not allow price information or promotional text in the header or description, and the asset must link to the same domain as the ad.

Does advertising a price replace a good faith estimate?

No. 45 CFR 149.610 sets separate requirements for good faith estimates of expected charges for uninsured (or self-pay) individuals. The advertised price and the estimate should agree.

Sources

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Advertising cash prices for a medical practice: bait offers, free offers and Google Ads price rules