Testimonials & Reviews in Mental Health Practice: Ethics, HIPAA, and the Post‑COVID Marketing Landscape
In the early days of COVID, when telehealth became a lifeline, mental health providers faced unprecedented demand. Many practices had no need to actively market — clients were finding them faster than they could be scheduled. Now, the landscape has shifted. With demand leveling in some areas, client acquisition once again requires intentional marketing strategies.
Marketing consultants and business coaches are responding to this shift by urging therapists to gather and feature client testimonials as a way to build trust and attract new clients. But for mental health professionals, this is not a simple business decision — it’s a complex ethical, legal, and relational issue. Testimonials, while common in other industries, carry significant risks in clinical contexts.
Before deciding whether and how to use testimonials, therapists must navigate professional ethics codes, HIPAA privacy rules, and the power dynamics inherent in the therapeutic relationship.
Ethics Codes: The Across‑the‑Board Prohibition
Every major U.S. mental health professional association has clear guidance prohibiting the solicitation of testimonials from clients who may be vulnerable to undue influence:
- APA (American Psychological Association) – Ethics Code 5.05: “Psychologists do not solicit testimonials from current therapy clients/patients or from other persons who because of their particular circumstances are vulnerable to undue influence.”
- ACA (American Counseling Association) – Code A.3.b: “Counselors are prohibited from soliciting testimonials from current clients or from former clients who may be vulnerable to undue influence.”
- NBCC (National Board for Certified Counselors) – Code 54: Counselors “shall not solicit testimonials from current clients or former clients who may be vulnerable to undue influence.”
- NASW (National Association of Social Workers) – Code 4.07(b): “Social workers should not engage in solicitation of testimonials from current clients or from other people who, because of their particular circumstances, are vulnerable to undue influence.”
- AAMFT (American Association for Marriage and Family Therapy) – Standard 3.8: “Marriage and family therapists do not solicit testimonials from current clients or from other persons who may be vulnerable to undue influence.”
This consistent prohibition recognizes that the therapist‑client power differential makes it difficult, if not impossible, for clients to feel entirely free to decline such a request without fearing it might affect their care or the relationship.
Across all major codes, the consistent prohibition is rooted in the power differential between therapist and client. Even without intentional coercion, the inherent imbalance can make a request feel obligatory to a client.
Importantly, some codes (like NBCC’s) extend this caution to former clients who may still be vulnerable. This is not a mere suggestion — it’s a professional mandate that protects clients from exploitation and safeguards the integrity of our field.
Once a Client, Always a Client: The Persistent Power Differential
A crucial consideration often overlooked in marketing conversations is the idea that, ethically and clinically, there’s rarely a clean break between “former” and “current” clients. The therapeutic bond doesn’t simply dissolve with the termination of an episode of care. Clients may return months or years later for additional support, and our responsibilities toward them — including those around privacy, boundaries, and avoiding exploitation — endure over time.
Even after the formal episode of care has been terminated, clients may:
- Return to therapy in the future with the same clinician.
- Continue to view the therapist as a trusted authority figure.
- Feel an ongoing emotional connection or loyalty to their therapist.
This is why ethics codes caution against, and in many cases prohibit, soliciting testimonials from former clients who could still be influenced by the prior therapeutic relationship. The safest interpretation is to treat all former clients as still potentially vulnerable — which, in practice, often means avoiding client testimonials entirely.
Even if a client initiates the offer of a testimonial, the inherent dynamics of the relationship mean it can be ethically complicated to accept or use it. Publicly featuring a client’s words (or even acknowledging that they were a client) could affect their willingness to return for care, influence the course of future therapy, or expose them to unintended privacy risks.
Approaching marketing with this understanding helps us avoid blurring lines between care and commerce — and reinforces the trust that is the foundation of effective therapy.
HIPAA: Marketing vs. Healthcare Operations
From a HIPAA standpoint, using a client’s words or experiences in marketing — even without explicitly naming them — generally counts as using Protected Health Information (PHI) for marketing purposes.This is different from disclosures for treatment, payment, or healthcare operations, which typically do not require separate authorization.
HIPAA defines marketing as a communication that encourages the use of a product or service when that product or service is not part of the client’s treatment, payment, or healthcare operations. Using a client testimonial on a website, social media post, or brochure to promote your services meets that definition — and requires a valid, signed HIPAA Authorization (not just a general consent).
HIPAA is explicit: if you are using a client’s information for marketing, you must have their signed authorization before doing so.
A signed Release of Information (ROI) can meet this requirement, but the relational and ethical issues remain. The existence of a legal release does not remove the potential for undue influence, nor does it address the power differential or the impact such a request can have on the therapeutic alliance — or on how the client feels about their care.
What About Using Survey Feedback?
It can be tempting to use positive feedback from a satisfaction or quality assurance (QA) survey in your marketing. However, doing so almost always runs afoul of both HIPAA and professional ethics codes — especially when the survey involves current clients.
Surveys of Current Clients
If a survey is sent to current clients, requesting feedback that you later want to use publicly (even if you ask permission after receiving their response), this is still solicitation of a testimonial from a current client. The ethics codes of the APA, ACA, AAMFT, NASW, and NBCC are clear and absolute on this point: there is no gray area — solicitation of testimonials from current clients is prohibited because of the inherent power differential and the potential for undue influence.
Even if you were to follow up with the client after the fact to ask permission, the act of collecting the feedback with marketing use in mind means the testimonial was, in effect, solicited during an active clinical relationship. This is precisely the kind of situation the prohibition is designed to prevent.
Anonymization, Unattributed Feedback, and Surveys
Some therapists consider sharing “anonymous” or unattributed client feedback — for example, pulling a statement from a satisfaction survey or email and removing the client’s name. While this might seem to solve HIPAA concerns, it rarely does in practice.
- HIPAA requirements: True de-identification under HIPAA’s Safe Harbor method means removing all identifiers — including those that might not be obvious to the public but could reasonably be used to determine identity. This includes indirect clues like timing, unique phrasing, or service details. Even if you believe the statement is “anonymous,” if the client themselves can recognize it, it is not truly de-identified.
- Marketing use still requires an ROI: Even if a quote is unattributed, if it is connected to a specific, identifiable client in your records, it is Protected Health Information (PHI) and cannot be used in marketing without a HIPAA-compliant Release of Information (ROI) specifically authorizing marketing use.
- Ethical considerations: Removing a name does not address the relational and ethical risks of undue influence — especially if the quote came from a current or recently terminated client.
Key takeaway: QA and satisfaction surveys should be designed and used exclusively for internal quality improvement — not as a source of marketing testimonials. If testimonials are desired, they must come from former clients, under ethically appropriate circumstances, and with a HIPAA-compliant ROI authorizing their marketing use.
Non-Clinical Staff and Testimonial Requests
It may be tempting to think that having a receptionist, administrative assistant, or marketing staff member request a testimonial circumvents the ethical barrier — but it doesn’t.
If the testimonial is being requested on behalf of the therapist or the practice, the same ethical restrictions apply. The request is still coming from the therapeutic entity, and the client may still feel undue pressure to comply.
Yelp, Google, and Dr. Keely Kolmes’ Guidance
Dr. Keely Kolmes, a psychologist and expert in digital ethics, has long cautioned mental health professionals against engaging with public review platforms in ways that could confirm someone’s client status.
In their widely cited Yelp Policy for Mental Health Professionals, Dr. Kolmes advises:
“If you use a review site such as Yelp or have a Google Business page, you cannot request or encourage clients to leave you reviews. You also cannot respond to reviews in a way that acknowledges the person is or was your client. Even a simple ‘thank you’ can confirm the reviewer’s status as a client, which is a HIPAA violation and an ethical breach.”
They recommend that therapists include a public statement on such platforms — and on their websites — explaining this policy. For example:
“Mental health professionals are ethically prohibited from soliciting or responding to testimonials from clients, in order to protect your privacy and confidentiality. While we cannot accept reviews from clients, we welcome feedback in other formats, such as direct communication.”
This approach both educates the public and sets a clear boundary, reducing the risk of privacy violations and ethical missteps.
Bottom Line
The combination of ethics codes, HIPAA requirements, and client trust creates a high-stakes environment where testimonials and reviews — powerful in other industries — are often a poor fit for mental health practices.
While marketing consultants and business coaches may promote these strategies, the safest and most ethical path is to build trust through educational content, community engagement, professional networking, and client experience excellence — not through use of client testimonials.
When in doubt, remember: your reputation is best built on ethics, integrity, and client trust — the very foundations of our work.
Leading with Trust and Integrity
In the world of private practice marketing, client testimonials can seem like low-hanging fruit. But for mental health professionals, they are a high-risk area where clinical ethics, privacy laws, and marketing ambitions intersect.
The safest, most sustainable approach is to build your reputation through thought leadership, professional visibility, and trust-based referrals — rather than client endorsements. This protects your clients, honors your ethical responsibilities, and reinforces the integrity of your practice.
In the end, the best marketing for a therapy practice isn’t just about attracting clients — it’s about modeling the very values and boundaries that make our work healing and safe.
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