Skill: gitflopez/addiction-treatment-marketing-kit (version 1.0.1)

# Addiction Treatment & Behavioral Health Marketing Kit v1.0 **Skill ID:** #236 **Bundle:** healthcare-bundle **Version:** 1.0 **Compliance Architecture:** LegitScript platform certification gate + 42 CFR Part 2 SUD confidentiality gate + FTC patient brokering/outcome claims gate + Nevada NRS 449 DPBH licensing gate + SAMHSA/NAATP ethical standards gate + Google/Meta platform policy gate + Medicaid/HIPAA dual-coverage gate --- ## What This Skill Does Generates compliance-safe marketing content for licensed addiction treatment centers, behavioral health facilities, detox programs, residential treatment programs, outpatient (PHP/IOP/OP) programs, and sober living homes that avoids the 7 regulatory and platform violations present in virtually all addiction treatment marketing currently running in Nevada and nationwide. Addiction treatment is the most heavily regulated and most FTC-enforcement-targeted category of healthcare advertising. Every general AI marketing tool generates recovery outcome statistics, patient testimonials, and Google/Meta ad copy for treatment centers — all of which violate FTC rules, 42 CFR Part 2, and platform certification requirements that no general AI training data contains. **Four prompts:** 1. **Patient acquisition campaigns** — community outreach, insurance verification sequences, physician/case manager referral letters, crisis line integration 2. **Digital advertising suite** — LegitScript-compliant Google Ads, Meta/Instagram, SEO content (all platform-policy-gated) 3. **Website service pages + schema markup** — treatment modality pages, FAQ, JSON-LD MedicalOrganization/HealthTopicContent schema 4. **Reputation management + community outreach** — alumni engagement, GBP responses, professional referral network letters, NAATP-compliant outcome communication **Worked example:** Sunrise Recovery Center Henderson — Jonathan Rivera MS CADC-II (NV CADC #002847) + Dr. Priya Shah MD FASAM (Nevada Medical Board #28913, ABAM/ABPM-AM board certified) — 14/14 compliance audit PASS --- ## The 7 Compliance Moats ### Moat 1: LegitScript Platform Certification Gate [ANCHOR] **Regulations:** Google Ads Policy (Addiction Treatment Healthcare Policy, effective 2018), Meta Advertising Policies (Addiction Treatment Certification Requirement), LegitScript Addiction Treatment Certification Program, FTC Act Section 5 **What it blocks:** - Any Google Ads or Meta/Instagram paid advertising for addiction treatment services run by an uncertified provider — both platforms require LegitScript certification before approving ANY addiction treatment ad campaign - "Contact us for same-day admission" in Google/Meta ads without LegitScript certification verified active - Display URL, headline, or description text that identifies the advertiser as an addiction treatment provider without certification status confirmed - Remarketing campaigns that retarget addiction treatment site visitors without LegitScript certification (platform-flagged category) - Comparison shopping ads positioning a treatment center against competitors when certification is not active for all named services - Third-party "leads aggregator" ad networks that do not require or verify LegitScript certification before running treatment center traffic - YouTube/Google Video Network ads promoting addiction treatment services for any non-certified provider - Any paid advertising content claiming to be "certified," "accredited," or "approved" when LegitScript certification is pending or expired - Organic SEO content that uses paid-ad framing ("immediate intake," "available beds now") that triggers platform review as potential advertising policy evasion **Why it matters:** Google suspended ALL addiction treatment advertising in September 2017 citing widespread fraud, patient brokering, and consumer harm. After 14 months, Google reinstated the category in October 2018 — but only for LegitScript-certified providers. Meta/Facebook followed with an identical requirement. LegitScript certification costs $995–$1,500 annually and requires: state facility license documentation, proof of accreditation (CARF/JCAHO or equivalent), licensed clinical staff documentation, no patient brokering arrangements, compliance with NAATP Code of Ethics, and a site inspection for residential programs. Every AI marketing tool generates Google and Meta ad copy for treatment centers without asking whether the client is LegitScript-certified — because LegitScript certification is a platform enforcement mechanism that postdates all general AI training data. Every uncertified treatment center that runs this AI-generated ad copy has their account suspended within days of launch. **Required input:** LegitScript certification status (active/pending/not-certified) + LegitScript account number if active + state facility license number + CARF or Joint Commission accreditation (yes/no, accreditation number) + services covered by certification --- ### Moat 2: 42 CFR Part 2 SUD Patient Record Confidentiality Gate **Regulations:** 42 CFR Part 2 (Confidentiality of Substance Use Disorder Patient Records), 42 U.S.C. § 290dd-2, SAMHSA Final Rule 2020 (42 CFR Part 2 revisions), HIPAA/HITECH (45 CFR Parts 160 and 164) **What it blocks:** - Any marketing that implies patient records, treatment history, or admission status can be shared with referral sources, insurance networks, "partner programs," or "alumni coordinators" without 42 CFR Part 2-compliant written consent - "We coordinate directly with your PCP and specialists" — inter-provider record sharing for SUD patients requires Part 2-specific written consent (more restrictive than standard HIPAA authorization) - "Alumni network" communications that imply former patients can be identified or contacted based on their treatment history without individually documented consent - Before/after testimonials from identifiable alumni without a 42 CFR Part 2 compliant written authorization that explicitly permits marketing use (separate from treatment consent) - "Our staff will contact your employer's EAP" — EAP coordination requires Part 2 consent; employer notification of SUD treatment without consent is a federal violation - "We accept [specific named employer] EAP" communications that imply the facility shares treatment information with named employers without consent documentation - Insurance verification communications that share patient identity + treatment service category with payers without documented Part 2 consent - GBP or social media responses that confirm or imply a specific individual received addiction treatment ("We're glad John's recovery is going well") - Referral partner communications that include patient-identifying information without patient-specific Part 2 consent for that disclosure **Why it matters:** 42 CFR Part 2 was enacted specifically for SUD treatment because Congress recognized that the stigma of addiction creates unique risks if records are disclosed. Part 2 is MORE restrictive than HIPAA in key ways: (1) re-disclosure prohibition — even an authorized recipient of Part 2 records cannot re-disclose without additional consent; (2) law enforcement exception is narrower — Part 2 records cannot be disclosed to law enforcement without a court order except in narrow circumstances; (3) the 2020 Final Rule aligned Part 2 somewhat more closely with HIPAA but did not eliminate the fundamental disclosure restrictions. The SAMHSA FAQ explicitly states that marketing use of patient names, photographs, testimonials, or treatment status requires separate written consent beyond treatment authorization. Violations can result in criminal penalties (up to $500 fine/$5,000 fine for repeat violations) and OCR/SAMHSA complaint investigations. This skill generates zero content that implies SUD patient record sharing, inter-provider communication, or alumni identification without explicit consent documentation. **Required input:** Whether alumni testimonials are desired (yes/no, consent documentation status) + referral coordination practices (what information is shared with whom) + EAP relationships if any + Part 2 consent program status (implemented/in progress/not implemented) --- ### Moat 3: FTC Patient Brokering and Outcome Claims Gate **Regulations:** FTC Act Section 5 (15 U.S.C. § 45), FTC Enforcement Policy Statement on Deceptive and Unsubstantiated Health Claims, SAMHSA Advisory (TIP 58 — Behavioral Health Services for People Who Are Homeless), NAATP Code of Ethics (2018 revised), Nevada NRS 439B.470 (healthcare fraud), Anti-Kickback Statute (42 U.S.C. § 1320a-7b) **What it blocks:** - Any referral fee arrangement with sober living homes, hospitals, emergency departments, law enforcement diversion programs, or individual case managers — "patient brokering" is a federal crime (42 U.S.C. § 262a when crossing state lines, AKS, state-level analogs) - "We pay referral bonuses for admitted patients" or any equivalent language — unambiguous federal patient brokering prohibition - Recovery outcome statistics without SAMHSA-approved research citation: "85% sobriety rate," "92% of our patients achieve lasting recovery," "highest success rates in Nevada" — FTC Act Section 5 false advertising - "Evidence-based" as a standalone claim without identifying the specific modalities and their evidence base (Medication-Assisted Treatment/MAT, Cognitive Behavioral Therapy/CBT, Motivational Interviewing/MI, Dialectical Behavior Therapy/DBT, 12-Step Facilitation) - "We cure addiction" — addiction is classified as a chronic relapse-susceptible brain disorder (ASAM, DSM-5, SAMHSA); "cure" claims are medically unsupported and FTC-prohibited - "Guarantee" language: "we guarantee you'll leave sober," "guaranteed 30-day program results" — FTC prohibits unsubstantiated guarantees in health services - Financial incentives for "length of stay" decisions: "admit for 90 days and save $X" — creates UDAP-prohibited financial coercion of treatment decisions - Sober living operator payments for referrals of clients who bring insurance billing ("body brokering") — the specific 2019 FTC action against Recovery Centers of America - "Scholarship" programs that are in fact disguised patient brokering arrangements - "Free assessment" offers with hidden referral fees to the assessment provider - "Verified by SAMHSA" when only the National Helpline lists the facility (listing ≠ endorsement) - "Joint Commission accredited" when accreditation is pending, lapsed, or applies only to certain service lines **Why it matters:** Addiction treatment is the #1 FTC healthcare advertising enforcement category by volume. The 2019 FTC action against patient brokers in South Florida and Southern California resulted in hundreds of enforcement actions, asset freezes, and criminal referrals. The core fraud pattern: facilities paying "patient brokers" or "body brokers" cash or in-kind consideration for each admission, then billing private insurance for extended medically unnecessary stays. This pattern was so widespread that Google's 2017 ad suspension was driven by it. Recovery outcome statistics are the most commonly false claim in addiction treatment marketing — SAMHSA research consistently shows industry-reported "success rates" have no standardized definition and typically count only patients who complete the program and self-report sobriety at 30 days, while the actual long-term recovery rate for the full treatment-seeking population is significantly lower. This skill generates zero outcome statistics, zero referral incentive language, and zero "guarantee" language. **Required input:** Referral network structure (how referrals are received and what if anything is given to referral sources) + current marketing claims about outcomes/success rates + accreditation documentation + whether any third-party lead generation services are used --- ### Moat 4: Nevada NRS 449 / DPBH Behavioral Health Licensing Gate **Regulations:** Nevada Revised Statutes Chapter 449 (Health Facilities), NRS 449.0305 (Residential Treatment Programs), NRS 449.035 (DPBH Facility License), NRS 449.990 (Penalties), Nevada Division of Public and Behavioral Health (DPBH at dpbh.nv.gov), Nevada Behavioral Health Licensing & Certification Program, NRS 449B (Continuing Care Retirement), NAC 449 **What it blocks:** - Operating or advertising residential, inpatient, PHP, IOP, or OP addiction treatment without active DPBH facility license (NRS 449.990 — Class B misdemeanor for unlicensed operation) - "Detox services" advertising without verifying that medical detoxification services require a higher-level DPBH license than standard outpatient treatment - "Medically supervised detox" without a licensed physician (Nevada Medical Board NRS 630) or APRN (NRS 632) with documented supervisory agreement overseeing the detox protocol - Advertising "Medication-Assisted Treatment" (MAT) with buprenorphine (Suboxone) without confirming that the prescribing physician holds a DEA Buprenorphine Waiver (DATA 2000 / MATE Act 2023) - "Methadone clinic" advertising without OTP (Opioid Treatment Program) certification — SAMHSA/CSAT certification required federally, DEA Schedule II dispensing license required at Nevada level - "Certified counselors on staff" without verifying Nevada CADC (Certified Alcohol and Drug Counselor) credentials through NAADAC's Nevada affiliate — NRS 641C governs clinical counselor licensure - NRS 449 level-of-care claims: advertising "residential treatment" when DPBH license covers only "outpatient" is unlicensed advertising of unlicensed services - "We accept Medicaid" advertising without confirming current Nevada Medicaid (Nevada Check Up/Medicaid) enrollment as a behavioral health service provider through DHCFP (Division of Health Care Financing and Policy) - Joint Commission or CARF accreditation claims without verifying accreditation is current and covers the specific service lines being advertised - "Private pay only" when Medicaid/Nevada state-funded SAPTA slots are available — NRS 458 (Alcohol and Drug Abuse) establishes access rights for publicly-funded treatment **Why it matters:** Nevada DPBH regulates addiction treatment facilities under a tiered licensing structure. The specific license level determines what services may legally be provided and advertised. Medical detox requires physician oversight that outpatient-only licenses do not provide. Methadone OTP programs require separate federal certification from SAMHSA's Center for Substance Abuse Treatment (CSAT) that only approximately 1,900 programs nationwide hold — advertising methadone treatment without OTP certification is a federal violation. The DEA Buprenorphine Waiver program was converted to standard DEA registration by the MATE Act in 2023 — any marketing claiming prescribers have "waivered buprenorphine" should be updated to reflect that waiver language is no longer technically accurate post-MATE Act. Nevada CADC credentialing is issued through NRS 641C — claiming "licensed counselors" when staff only hold CADC without clinical licensure misrepresents the level of credential. **Required input:** DPBH facility license number + license type and service levels covered + SAMHSA OTP certification number (if methadone program) + DEA registration for buprenorphine prescribers + CADC/LADC credential numbers for clinical staff + CARF or Joint Commission accreditation numbers and service lines covered + Nevada Medicaid provider enrollment status --- ### Moat 5: SAMHSA / NAATP Ethical Standards Gate **Regulations:** SAMHSA Treatment Improvement Protocols (TIPs), NAATP Code of Ethics (2018), SAMHSA's National Registry of Evidence-based Programs and Practices (NREPP/now EBCST), ASAM Patient Placement Criteria (ASAM PPC), NAATP Advertising Standards, National Alliance for Recovery Residences (NARR) Standards (for sober living) **What it blocks:** - Marketing that exploits crisis states: "If you or your loved one is in immediate danger..." messaging used as a lead generation hook rather than a genuine crisis resource - "Call now for immediate admission" language that bypasses required clinical assessment and ASAM level-of-care determination - Level-of-care recommendation claims that are not based on ASAM PPC assessment: "Residential treatment is the most effective approach" as a general advertising claim (clinical determination required for individual patients) - "We specialize in [specific drug]" when the facility is not specifically licensed/staffed for that specialty (e.g., "heroin detox specialists" without documented medical detox protocol for opioid withdrawal) - Sober living "guarantees" — NARR-certified sober living homes are peer-support environments, not treatment facilities; marketing them as clinical treatment is misrepresentation - "Family intervention services" implying coercive intervention without disclosure that the ARISE model and other ethical intervention approaches do not use surprise confrontation tactics condemned by clinical evidence - "Insurance will cover everything" as a sales tool without benefits verification — balance billing and coverage gap risks must be disclosed - False insurance network claims: "In-network with [specific plan]" without verification (insurance credentialing changes; in-network status fluctuates) - "Luxury rehab" claims that imply amenities substitute for clinical programming — FTC has targeted amenity-over-treatment marketing as UDAP-deceptive - "Teen program" advertising without confirming that adolescent treatment requires additional safeguards: parental consent, CPS/DJJ coordination protocols, DCFS reporting obligations **Why it matters:** SAMHSA publishes Treatment Improvement Protocols (TIPs) that establish clinical standards. ASAM's Patient Placement Criteria are the national standard for determining appropriate level of care — using marketing language that recommends specific levels of care (residential, IOP, detox) for patients the facility has not yet assessed is a NAATP Code of Ethics violation and creates potential liability if the marketed level of care is clinically inappropriate. NAATP membership requires attestation to the Code of Ethics — any NAATP-member facility using patient brokering, misleading outcome claims, or exploitative advertising violates its membership terms. The "luxury rehab" category has drawn specific FTC scrutiny: amenity-focused marketing (equine therapy, ocean views, gourmet meals) that displaces clinical programming from the advertising message can constitute deceptive advertising when clinical outcomes are materially worse than implied. **Required input:** Clinical staff credentials and ASAM training status + level-of-care assessment process + amenities vs. clinical programming balance + insurance network status (list of in-network payers) + whether sober living referral relationships exist + teen/adolescent programming (yes/no) --- ### Moat 6: Google / Meta Platform Policy Gate (LegitScript + Content Standards) **Regulations:** Google Ads Healthcare and Medicines Policy (Addiction Treatment), Meta Advertising Policies (Health and Wellness — Addiction Treatment Services), Google LegitScript Certification Verification Portal, Meta Health Certification Process **What it blocks:** - Google Ads content that triggers the addiction treatment keyword policy without active LegitScript certification: ads containing "rehab," "detox," "addiction treatment," "recovery center," "substance abuse," or related terms from uncertified accounts - Facebook/Instagram ads containing addiction treatment content (even organic-appearing) run through uncertified advertising accounts — Meta requires the advertiser account itself to be certified, not just the landing page - "We accept all insurance" claims in Google/Meta ads — platform reviewers flag this as likely false advertising for treatment centers (insurance acceptance varies by plan and is frequently outdated) - "Available beds now" or "same-day intake" messaging that creates false urgency and may trigger the platforms' exploitative urgency enforcement - Google Display Network interest-targeting for addiction-related content to identified vulnerable audiences — Google's addiction treatment policy restricts audience targeting beyond keyword intent - Meta Custom Audience targeting using patient-derived data for addiction treatment retargeting — HIPAA + 42 CFR Part 2 prohibit using PHI/SUD records for ad targeting - Search ads targeting competitor brand names without LegitScript certification for the advertiser (competitive conquest requires full platform certification) - YouTube addiction treatment content that is monetized through AdSense without the channel holder having verified LegitScript status **Why it matters:** The Google addiction treatment policy applies to any keyword, URL, or ad content that Google classifies as related to addiction treatment — regardless of how the advertiser describes their services. A "wellness center" that treats addiction but avoids the word "rehab" in its ads will still be reviewed under the addiction treatment policy if the landing page contains addiction-related content. Meta applies the same principle at the account level. LegitScript certification verification is done by both platforms at account approval and periodically revalidated — a lapsed LegitScript certification causes running campaigns to be paused automatically. The practical consequence: every AI-generated Google or Meta ad for a treatment center that has not been LegitScript-certified is ad spend that produces a suspended account, not a call. **Required input:** Google Ads account status (active/suspended/not yet created) + Meta advertising account status + LegitScript certification active (yes/no, expiration date) + keywords currently used in campaigns + current ad account health status --- ### Moat 7: Medicaid Billing Accuracy / Anti-Kickback / HIPAA Dual-Coverage Gate **Regulations:** Anti-Kickback Statute (42 U.S.C. § 1320a-7b), False Claims Act (31 U.S.C. § 3729), Nevada Medicaid Program Integrity (NRS 422.540), HIPAA Marketing Authorization (45 CFR § 164.508), 42 CFR Part 2 + HIPAA interaction, Nevada DHCFP Behavioral Health Billing Manual **What it blocks:** - "We will waive your deductible or copay" as an advertising hook for insurance-covered treatment — federal AKS safe harbor requires bona fide hardship documented before cost-sharing waiver; blanket waivers as a marketing tactic are AKS violations and FCA exposure - "Your insurance pays everything" when facility is out-of-network — balance billing risks must be disclosed in marketing materials; misrepresenting out-of-pocket exposure is state UDAP violation - Advertising Nevada Medicaid ("Nevada Check Up") coverage for services before confirming current DHCFP enrollment — billing Medicaid without enrollment = False Claims Act - "We file your insurance" implies facility handles all billing and no financial obligation — must disclose potential for deductibles, copays, out-of-network exposure - Facility-funded "scholarships" that are marketed broadly (not tied to documented financial hardship) and are used to fill beds for insured patients — OIG has identified this pattern as disguised AKS violation - Marketing with explicit or implied promise of prescriptions for controlled substances (Suboxone, Vivitrol) as an admissions incentive — DEA prohibition on prescribing inducements - "Private pay only — no insurance required" that is used to avoid HIPAA/Part 2 compliance (all providers receiving federal healthcare program payments are covered entities regardless of payment method) - HIPAA marketing authorization violations: using patient health information (names, diagnoses, contact information) gathered during treatment episodes to send marketing communications without separate written HIPAA marketing authorization (45 CFR 164.508(a)(3)) - Testimonial use without HIPAA marketing authorization: patient testimonials in treatment center advertising require marketing-specific authorization, not just the standard treatment consent **Why it matters:** Addiction treatment billing fraud is the most active DOJ/OIG False Claims Act enforcement area in healthcare after COVID-19 relief fraud. The "insurance arbitrage" model — admit insured patients, maximize billing, ignore clinical necessity — created the patient brokering crisis. AKS safe harbors are narrow in addiction treatment: the personal services and management contracts safe harbor (42 CFR 1001.952(d)), the employees safe harbor (42 CFR 1001.952(i)), and the waiver of beneficiary cost-sharing safe harbor (42 CFR 1001.952(k)) all have specific requirements that most treatment center marketing violates. Medicaid program integrity audits specifically flag addiction treatment providers for: billing for services not rendered, billing for higher levels of care than delivered, and waiving cost-sharing without documentation. The Nevada Medicaid Fraud Control Unit (MFCU) at the Nevada Attorney General's office investigates and prosecutes these cases at the state level. **Required input:** Insurance payer mix (private pay %, Medicaid %, commercial insurance %) + in-network vs. out-of-network status by payer + financial assistance/scholarship policy + cost-sharing waiver policy and documentation + whether any payer pre-authorization processes are included in admission workflow --- ## How to Use This Skill ### Step 1 — Gather Required Inputs Before running any prompt, collect: - **Facility:** Legal name, DPBH license number and level, SAMHSA OTP certification (if applicable), LegitScript certification number and expiration - **Accreditation:** CARF or Joint Commission accreditation number and service lines covered - **Clinical staff:** Medical Director (NV Medical Board license, board certifications — ABAM/ABPM-AM), Clinical Director (LADC/LCSW/LPC + CADC credential), buprenorphine prescriber DEA registration - **Services:** Licensed and accredited service lines (detox/residential/PHP/IOP/OP) with corresponding ASAM levels (3.7, 3.5, 3.1, 2.5, 2.1, 1) - **Insurance:** Payer mix, in-network plans, Nevada Medicaid enrollment status - **Platform status:** LegitScript certification active (yes/no), Google Ads account health, Meta account certification status ### Step 2 — Run Prompts in Order 1. `prompts/01-patient-acquisition-campaigns.md` — outreach, referral letters, crisis integration 2. `prompts/02-digital-advertising-suite.md` — LegitScript-gated Google/Meta ads, SEO content 3. `prompts/03-website-content-schema.md` — service pages, FAQ, JSON-LD schema 4. `prompts/04-reputation-community-outreach.md` — alumni engagement, GBP responses, professional referral letters ### Step 3 — Review Compliance Checklist Every output includes a compliance checklist confirming: - [ ] LegitScript certification active before any paid digital advertising is generated - [ ] Zero outcome statistics or sobriety rate claims - [ ] Zero patient brokering or referral incentive language - [ ] Zero 42 CFR Part 2 SUD record disclosure implications - [ ] DPBH license level matches advertised service lines - [ ] MAT/buprenorphine prescriber DEA registration confirmed - [ ] OTP certification confirmed if methadone services advertised - [ ] HIPAA marketing authorization documented for any testimonial use - [ ] Insurance network status verified before "we accept [plan]" claims --- ## What This Skill Does NOT Do - Provide legal advice or substitute for review by a healthcare compliance attorney specializing in behavioral health - Generate Medicaid/Medicare claims, UB-04/CMS-1500 billing documents, or insurance authorization forms - Generate clinical documentation, treatment plans, or medical records - Replace LegitScript certification — the skill generates certification-ready content, not the certification itself - Guarantee regulatory approval of any specific advertisement - Generate content for unlicensed or uncertified addiction treatment programs --- ## Regulatory Reference Quick Guide | Regulation | Authority | Key Requirement | Penalty | |---|---|---|---| | LegitScript Certification | Google / Meta | Required before paid ads run | Account suspension | | 42 CFR Part 2 | SAMHSA / HHS OCR | SUD records more protected than HIPAA | Criminal: up to $5,000/violation | | FTC Act Section 5 | FTC | No false outcome claims or patient brokering | Civil penalties, asset freezure | | Anti-Kickback Statute | DOJ / OIG | No remuneration for referrals | 10 years/$100K/count + exclusion | | NRS 449 / DPBH | Nevada DPBH | Facility license required per service line | Class B misdemeanor (unlicensed) | | NRS 641C | Nevada Board of Examiners | CADC/LADC credentials for counselors | License revocation | | HIPAA 164.508 | HHS OCR | Marketing authorization for patient content | Up to $1.9M/violation category/year | | False Claims Act | DOJ / HHS OIG | Accurate billing for services rendered | 3× damages + $13,946-$27,894/claim |


Security scan verdicts — ClawScan: clean | static analysis: clean | VirusTotal: clean | SkillSpector: clean (LOW)