Chiropractic new patient offers: exams and rewards

“Free first exam.” “$29 new patient special.” “Refer a friend, get a free adjustment.” “We waive your copay.” These offers are everywhere in chiropractic marketing, and some of them can create real legal exposure, especially for practices that see Medicare or Medicaid patients. This guide explains what the federal rules say, where state rules come in, and how to bring in new patients in ways that do not depend on giveaways. For how a chiropractor gets found in local search, see chiropractic SEO.

This is not legal advice. It summarizes federal guidance from the HHS Office of Inspector General (OIG), CMS and the FTC as we read it in October 2026. State laws and state chiropractic boards have their own rules on advertising, discounts, free services and referral payments, and they differ from state to state. Before you run any offer, check it with a healthcare attorney and your state board’s current rules. Free consultations at other kinds of practices, including the Florida 72 hour statement, are covered in our guide to free consultation offers.

The federal rules in plain words

Two federal laws matter most for patient offers. Both are about patients covered by federal health care programs such as Medicare and Medicaid.

The Anti-Kickback Statute (42 U.S.C. 1320a-7b(b)). OIG describes it as a criminal law that prohibits knowingly and willfully paying “remuneration” to induce or reward referrals or business involving items or services payable by federal health care programs. Remuneration includes anything of value. OIG also says the prohibition applies to all sources of referrals, even patients.
The beneficiary inducement law (42 U.S.C. 1320a-7a(a)(5)). OIG explains that it imposes civil monetary penalties on providers who offer remuneration to Medicare and Medicaid beneficiaries to influence them to use their services. OIG’s bulletin on gifts and inducements notes that the statute’s definition of remuneration includes waivers of copayments and deductibles and items or services given for free or for less than fair market value.

In other words: for federal program patients, “free” and “discounted” are not just marketing words. They can be remuneration.

Waiving copays and deductibles

“We waive your copay” is the offer with the clearest federal guidance. OIG’s guidance for physicians says that where Medicare and Medicaid require patients to pay copays, you are generally required to collect them, that routinely waiving copays could implicate the Anti-Kickback Statute, and that you may not advertise that you will forgive copayments.

The same guidance says what is allowed: you may waive a copayment if you make an individual determination that the patient cannot afford to pay, or if your reasonable collection efforts fail. It also says it is legal to provide free or discounted services to uninsured people.

OIG’s older Special Fraud Alert on routine waivers of Medicare Part B copayments lists warning signs, including routine use of “financial hardship” forms without a good faith look at the patient’s actual finances, and collecting copays only from patients who have supplemental coverage. If any of that describes how your front desk works, talk to your attorney.

Free exams, gifts and giveaways

For Medicare and Medicaid beneficiaries, OIG has set a limit for gifts that do not need to fit a legal exception. Its December 2016 policy statement interprets “nominal value” as a retail value of no more than $15 per item or $75 in total per patient per year, and says the items may not be cash or cash equivalents. A gift card is a cash equivalent.

Above those limits, an offer needs to fit one of the statutory exceptions, such as a cost-sharing waiver based on financial need, or be covered by a favorable OIG advisory opinion for your own arrangement. A free exam, free X-rays or a free adjustment given to a Medicare patient to win their business is a free service, so it is worth checking with your attorney before advertising it to that group.

It also helps to know what Medicare covers. The CMS Medicare Benefit Policy Manual says Medicare coverage of chiropractic services extends only to manual manipulation of the spine to correct a subluxation, and that other services furnished or ordered by chiropractors are not covered. That affects how you explain costs to Medicare patients, and it is one more reason to write offers carefully for them.

“Refer a friend” rewards

Patient referral programs are common, and they are where the Anti-Kickback Statute’s reach surprises people. Because OIG says the prohibition applies to all sources of referrals, even patients, a reward for referring a patient whose care is paid by a federal health care program needs careful review. State rules on paying for referrals or splitting fees differ, and a state law can apply regardless of who pays for care; check your state’s statutes and chiropractic board rules. A thank-you note costs nothing and carries none of that risk.

If you do advertise “free” or a discount

For patients outside federal programs, offers may be allowed, subject to your state’s rules. If you run one, the FTC’s Guide Concerning Use of the Word “Free” (16 CFR Part 251) sets out what fairness requires:

All terms, conditions and obligations should be stated clearly and conspicuously at the outset of the offer, close to the word “free”, so no one can reasonably misunderstand it.
A “free” item offered with a purchase is understood to be based on the regular price of what must be bought, so that price should not be raised to cover the free item.

In practice: say who the offer is for (for example, new patients without federal program coverage, if that is what your attorney advises), what it includes, what it does not, and when it ends. Never let a “free exam” turn into a pressured sale of a long prepaid plan.

Claims about what chiropractic treats

Offers are not the only risk in chiropractic ads. The FTC’s Health Products Compliance Guidance says claims about the health benefits or safety of health-related products generally need competent and reliable scientific evidence, and the FTC Act’s ban on deceptive advertising applies to services too. Google’s Unreliable claims policy does not allow unproven claims of cures. Keep ads and pages to the care you provide and the conditions your practice can support with evidence, and leave out claims about treating unrelated illnesses.

How to get new patients without giveaways

Many chiropractic patients find a practice through a local search, often on a phone. That is where the steady, rule-safe work pays off:

Show up in the mapAn accurate Google Business Profile with the right categories, real photos and hours that match when you answer. See our Business Profile guide.
Be clear about cost instead of freePublish what a first visit includes, which plans you work with, and your cash-pay options. Clear prices and terms answer the question a “free” offer tries to answer, without the legal questions.
Make booking easyA tap-to-call number and a request or booking link on every page, and an answer when people call at the busy times you are adjusting patients.
Earn reviews the right wayAsk every patient the same way, with no reward. Our patient review guide has wording and reply templates.
Explain the first visitWhat happens, how long it takes, whether imaging is involved and whether treatment can start the same day. Many people hesitate because they do not know.

How we approach it

Our chiropractic marketing work focuses on local search, clear first-visit and pricing pages, a review process every patient gets, and an AI front desk for the calls you cannot take mid-adjustment. We do not buy referrals or run reward schemes, and we ask you to confirm any offer with your own counsel and your state board before it goes on the site or into an ad.

Frequently asked questions

Can a chiropractor offer a free first exam?

It depends on who the offer reaches and your state’s rules. For Medicare and Medicaid patients, OIG treats free services as remuneration under the beneficiary inducement law unless an exception applies. For other patients, state rules and the FTC’s guidance on “free” offers apply. Check with your attorney and state board first.

Can we advertise that we waive copays?

For Medicare and Medicaid patients, no. OIG says you are generally required to collect copays, that routinely waiving them could implicate the Anti-Kickback Statute, and that you may not advertise that you will forgive them. Individual waivers based on financial need, or after reasonable collection efforts fail, are allowed.

What gifts can we give Medicare patients?

OIG’s 2016 policy statement allows items with a retail value of no more than $15 each and $75 in total per patient per year, and not cash or cash equivalents such as gift cards, without needing a legal exception.

Is a refer-a-friend reward allowed?

OIG says the Anti-Kickback Statute applies to all sources of referrals, even patients, so rewards tied to referrals of federal program patients need careful legal review, and state referral and fee-splitting rules differ, so check yours. A simple thank-you is the low-risk option.

Do these rules apply to cash-only practices?

The federal laws above concern federal health care program business, so a practice that truly takes no federal program patients faces less of that risk. State laws and board rules can still apply to discounts, free services and referral payments, and the FTC’s rules on advertising apply to everyone.

Sources

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Chiropractic new patient offers: free exams, discounts, copays and referral rewards