A free guide from Cima Consulting
How to market a treatment center legally (and actually fill it)
Where admissions really come from for an outpatient program or practice, how to build referral relationships without breaking patient brokering laws, which listings matter, what your website needs, the rules on reviews, and how to measure admissions by source. From operators who run a licensed Texas PHP, IOP and outpatient program.
Updated October 24, 2026. Not legal advice: Cima Consulting isn't a law firm, so run every marketing contract, vendor and referral arrangement past your own health-care attorney.
The short answer: most outpatient admissions come from people who already see your future clients: hospitals, detox and residential units stepping clients down, therapists, primary care, EAPs and courts. Earn those referrals with fast intake and good communication, never with anything of value. Then make the program easy to find (Google Business Profile, FindTreatment.gov, plan directories and, for practices, Psychology Today), give it a website that answers "can I start, and will insurance pay?", get LegitScript certified before any addiction ads, and count every inquiry and admission by source each month.
1. Start with the rules
Treatment marketing has a history of patient brokering, and the laws are strict: EKRA (18 U.S.C. 220) covers licensed substance use treatment facilities, recovery homes and labs for every payer; the federal Anti-Kickback Statute covers Medicare and Medicaid; and the Texas Patient Solicitation Act covers every licensed provider and every payer, self-pay included. Three working rules follow:
- Pay for advertising, never for patients. A flat fee for an ad, a listing or a website is advertising. A fee per call, lead or admission is paying for referrals.
- Pay people a fixed salary or fee, set in advance at fair market value, never a bonus tied to admissions or census.
- Give referral sources nothing of value. Not gift cards, not meals, not tickets. Give them fast admissions and useful updates instead.
Our guide to patient brokering laws walks through the traps in detail: per-admission marketers, bought call-center leads, free housing or travel, and lab "fees".
2. Where admissions come from
List these before you spend a dollar on ads. For each, write down who the decision-maker is, what they need from you, and how a referral reaches you.
| Referral source | Who to meet | What they need from you |
|---|---|---|
| Hospitals and emergency departments | Social workers, case managers, discharge planners, psychiatric consult teams | Same- or next-day assessment, the insurance you take, a direct phone line that's answered |
| Detox, residential and inpatient psychiatric units | Discharge planners and clinical directors | A step-down to PHP or IOP that starts before the client loses momentum; a schedule that works with transportation and jobs |
| Therapists, psychiatrists and primary care | Private practices and clinics near you | A clear picture of who fits your levels of care, and their client back when the program ends |
| Employee assistance programs | EAP case managers; employer HR | Evening tracks, work notes, return-to-work coordination with consent |
| Courts, probation and specialty courts | Probation officers, drug court coordinators, defense attorneys | Attendance and progress reports, sent only with the client's 42 CFR Part 2 consent |
| Schools, colleges and community groups | Counseling centers, faith and recovery communities | Education talks, a simple way to refer, and somewhere to send families |
| Recovery residences | House managers and owners of certified homes | Clinical care residents choose freely, with no money or rent tied to attendance (EKRA covers recovery homes) |
| Self-referrals and families | People searching at 11 p.m. | A findable listing, a website that answers their questions, and a human on the phone |
3. Referral relationships, done right
This is the step on our launch roadmap that brings in the first months of census: visit the people who'll send you clients, and the ones you'll send clients to. What works:
- A one-page program summary. Levels of care (PHP, IOP, OP), hours and tracks, who you serve, admission criteria in plain language (based on The ASAM Criteria for substance use), insurance accepted, address, and one phone number answered by intake.
- A simple way to refer. A phone line, a secure fax or e-referral, and a named intake contact. Promise a call back within a set time, and keep the promise.
- Close the loop, with consent. With the client's written consent, let the referrer know the client was admitted, how they're doing and when they discharge, and send them back to their therapist or psychiatrist with a discharge summary. For substance use records, use consent forms that meet 42 CFR Part 2.
- Refer out when you're not the right fit. A client who needs detox or residential care goes there, even to a program you compete with. Referrers notice, and admissions must rest on clinical need anyway.
- Keep it clean. Nothing of value for referrals, no referral swaps, and no deals with anyone who promises to "fill beds". Every outreach person's pay is fixed, and every partner arrangement is in writing and reviewed by your attorney.
- Tell partners when you open, and when anything changes: a new track, a new insurance contract, new hours. Update the website and listings the same day.
One outreach visit to a discharge planner who then can't reach your intake line does more harm than no visit. Fix intake first.
4. Fast intake is marketing
The program that answers, verifies benefits and offers a start date first usually gets the client. That's an operations problem, and the fixes are concrete:
- Answer every call live in business hours, and return after-hours messages first thing. A voicemail box is where referrals go to die.
- Verify benefits in minutes, not days. Know what to ask for each level of care and whether a prior authorization is needed; our VOB checklist for treatment admissions lists it.
- Offer an assessment the same or next day, and admit at the right level of care with an authorization in place when the plan requires one (the prior authorization guide covers the timing).
- Track every inquiry, including the ones that don't admit and why: wrong level of care, no coverage, no show. That list tells you what to fix.
5. Google Business Profile
For a local program, the free Google Business Profile is often what people see first on Maps and in search. Set it up at your licensed address (part of our website and directory listings service, $950):
- Your real name and address, the same as on your license, sign and website, following Google's guidelines for representing your business. Keep the name, address and phone identical everywhere you're listed.
- Categories, hours and services that match what you're licensed for: the levels of care, adult or adolescent, substance use or mental health, and the insurance you take.
- Your own photos of the building, group rooms and entrance, never stock images.
- The phone number intake answers, and a link to your website's "how to start" page.
- Answer questions posted on the profile and reply to reviews within the rules below.
6. Directory listings that matter
| Listing | Who it's for | Notes |
|---|---|---|
| FindTreatment.gov (SAMHSA) | State-licensed substance use and mental health treatment programs | Free, run by the federal government, and searched by people and referrers. Request a listing once your license is issued, then check that levels of care, payment types and services are right. |
| Insurance plan provider directories | Every in-network program and practice | Members search their plan's directory. After each contract is effective, check your listing's address, phone, services and "accepting new patients". See credentialing for getting in network. |
| Psychology Today | Therapists, group practices and prescribers | A paid profile. List the plans you actually take, your specialties and a photo; it's included in our Solo Practice: Complete launch. |
| Recovery residence directories | Sober living homes | In Texas, TROHN certification and its directory; see our sober living guide. |
Be wary of paid "rehab directories" and "helplines" that charge per call or route callers to whoever pays. LegitScript treats lead generators and directories that send callers to providers they don't own as ineligible to advertise, and per-call fees raise patient brokering questions.
7. A website that works
The site answers the questions a scared person or a busy discharge planner has, in this order:
- Who you help and what you offer: levels of care, hours and tracks, adults or adolescents, substance use, mental health or both.
- Insurance and cost: the plans you're in network with, and what happens if theirs isn't one of them.
- Where you are: the physical address of each licensed location, parking and transit, with real photos.
- How to start: one phone number, intake hours, and what happens on the first call and first day.
- Who's on staff: real names and credentials (LCDC, LPC, LCSW, physician), and the license and accreditation you hold.
- Your privacy notice, and the fine print a careful reader looks for.
- Use your EHR's secure inquiry or booking link and keep client details off unsecured web forms. Our website service includes the booking link from your EHR; for a program, Cima EHR for IOP and PHP keeps levels of care, authorizations and group notes in one place.
- Be careful with tracking pixels. HHS has published guidance on online tracking technologies under HIPAA; health information sent to an ad platform from an intake page can be a HIPAA and Part 2 problem. Keep pixels off intake and appointment pages and ask your attorney.
- No outcome promises. "Guaranteed sobriety" or success rates you can't support break platform rules and can break Texas law on treatment facility marketing (Health and Safety Code 164.010).
8. Paid ads
Addiction treatment ads on Google and Meta in the U.S. require LegitScript certification first, then each platform's own approval. Mental-health-only programs and therapy practices usually aren't under the addiction policy unless their ads promote substance use treatment. Before you buy ads:
- Get the license, the website and the intake line right, so paid clicks don't land on a voicemail.
- Use your own ad accounts and phone numbers. An agency can manage them, for a flat or hourly fee, not a fee per admission.
- Measure cost per admission by campaign, not clicks (section 10).
9. Reviews: the rules
- Never buy, fake or trade reviews, and don't have staff or their families post them. The FTC's rule on consumer reviews and testimonials (16 CFR Part 465) bans fake reviews and paying for reviews, and the review sites ban it too.
- Ask fairly. Ask alumni at a natural point, such as after discharge, and ask everyone the same way, not only the clients you expect to be happy. Don't ask people in crisis.
- Never confirm someone was a client when you reply. Saying "we're sorry your stay went that way" discloses that they were a client, which is protected under HIPAA and, for substance use care, 42 CFR Part 2. Reply in general terms and invite them to call.
- Don't put client stories on the site without written authorization, and never ones that promise results.
10. Measure admissions by source
Ask every caller how they heard about you, record it in the chart or intake log, and review the numbers every month alongside census and collections. Nothing here is ever used to pay anyone per admission.
| Measure, by source | What it tells you |
|---|---|
| Inquiries | Which partners and channels are sending people at all |
| Assessments and admissions, and the share of inquiries that admit | Whether a source sends people who fit your levels of care and insurance; a low rate means a mismatch to fix with that partner |
| Days from first call to first session | How fast intake is; the number referrers feel most |
| Reasons for not admitting | Coverage you don't have, a level of care you don't offer, or calls that weren't returned |
| Completions and step-downs | Whether clients from each source finish; what you report back to partners, with consent |
| Cost per admission for ads and paid listings | Which flat-fee spending is worth keeping |
Our operator advisory ($1,250 per month) includes a monthly check-in on these numbers and compliance with someone who runs a program.
11. The launch sequence
On our Texas roadmap, marketing steps run in this order, with the planning time we give each. The IOP / PHP Program Launch carries all of them, alongside the license and payer contracts.
| Step | When | Planned time |
|---|---|---|
| Learn the rules on paying for referrals, with your attorney | Before any marketing deal | 3 days |
| Build the website | Once the entity, phone and email exist | 2 weeks |
| Google Business Profile and directories | Once you have the site and the address | 1 week |
| FindTreatment.gov listing | Once the state license is issued | 2 weeks |
| LegitScript certification (substance use programs) | After the license and the website | About a month |
| Meet referral partners | After the rules and the website | About a month, then ongoing |
| Tell partners your opening date | Just before opening | 3 days |
Then, every month: the numbers by source, a note to each active partner, and listings checked against reality. For the whole opening path see how to start an IOP or PHP in Texas or, for a practice, how to start a private practice in Texas.
Questions
How do treatment centers get referrals?
Mostly from people who already see the clients: hospital and ED social workers, detox and residential discharge planners, therapists, psychiatrists, primary care, EAPs and courts, plus families who find the program online. Programs that answer the phone, admit quickly and keep referrers updated (with consent) get more of them. Paying or giving anything of value for referrals is illegal.
Can I hire a marketing company for my treatment center?
Yes, if it's paid a flat or hourly fee for defined work (website, ads management, content), uses your name and phone number, and never charges per call, lead or admission. Have your attorney review the contract before you sign.
Can I pay a referral coordinator or outreach rep?
Yes, a fixed salary set in advance at fair market value. Not commissions or bonuses tied to admissions, census or revenue, which is what EKRA's employee exception excludes.
Is it worth listing on FindTreatment.gov?
Yes, for a licensed program. It's free, run by SAMHSA, and used by people looking for care and by referrers. Keep the listing accurate as services change.
How much should a new program spend on marketing?
Start with what's free or flat: the Google Business Profile, FindTreatment.gov, plan directories and referral visits. Add a website (our service is $950) and, once LegitScript certified, ads you can measure by cost per admission. Size the rest from your break-even census, not a percentage someone quotes.
Should I ask clients for Google reviews?
You can ask alumni, fairly and the same way for everyone, but never pay or offer anything for a review, never post fake ones, and never confirm in a reply that the reviewer was a client.
Want this set up for you?
Website and directory listings: $950. Operator advisory, with a monthly look at your numbers: $1,250 per month. Opening a program from scratch? It's all in the IOP / PHP Program Launch.
Sources
- 18 U.S.C. 220 (EKRA): Cornell LII; Texas Legislature, Occupations Code chapter 102
- SAMHSA, FindTreatment.gov
- Google, Guidelines for representing your business on Google; Addiction services ad policy
- LegitScript, Addiction Treatment Certification (eligibility, lead generators and directories)
- eCFR, 42 CFR Part 2 and 16 CFR Part 465 (consumer reviews and testimonials)
- HHS, Use of online tracking technologies by HIPAA covered entities
- ASAM, The ASAM Criteria; Texas Health and Safety Code, Section 164.010
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