Beyond your website: directories, lists, reviews and doctor-bylined articles

6.1 Before you send any letter: letter of appointment, sign-off sheet, banned-word list

What you'll do in this section: Before you send the first outreach letter, get three things in place: the letter of appointment on file, this batch's sign-off sheet signed, and zero banned-word hits in the materials. If you can't get the letter of appointment, all that is left of off-site work is website-side work. Don't send letters first and sort out the paperwork afterwards.

The letter of appointment comes first, because without it you don't even have the right to publish on the client's behalf: publishing externally with no appointment is itself a breach of the rules, and the publishing party is directly liable (Statute text; see Appendix A.1). The licence holder signs the letter of appointment, stating which services you are appointed to publish on their behalf, with the licence number, the scope of authorisation, the term, and how it can be revoked. Without it, all you can do is website-side work (/facts and filling in the five business profiles yourself, see 3.1, 3.4). The whole main line of work, six-trace alignment and third-party corrections, is gone: you cannot send even one correction letter.

The sign-off sheet is one per batch, listing item by item the facts sent to the third party in this batch (price, registration number, an 80-word description, photo permissions); the signatory confirms they are true and authorises publication. Without it, if the third party publishes them as given and something goes wrong, the liability lands on you. The banned-word gate runs this batch's materials through the Annex A Chinese–English mapping table (skeleton in Appendix B.3); the batch goes out only with zero hits.

The two documents settle "whether you have the right to publish on the client's behalf" and "whether both sides have confirmed this batch's facts". They do not settle the compliance judgement itself. A written sign-off resolves only the three stop-and-escalate situations in 1.1; it never turns something banned as Statute text into something publishable. Even after the client's compliance officer has signed, the publishing party is not released from liability: under the regulations, the party publishing on the client's behalf is already jointly liable with the licensee (Statute text; see Appendix A.1). File the sign-off sheet together with the letter of appointment.

Two common mistakes: publishing material externally as the client's agent without a letter of appointment; sending review-request templates for a dental or aesthetic clinic (see 6.5 for why they can't be sent).

6.2 Paid listings, Best / Top lists and removal requests

What you'll do in this section: Spend money on only two kinds of page: pure directory entries with no laudatory terms, listed alphabetically or in sequence and not highlighting any one business; and price-comparison pages. For "Best / Top N" pages, whether marked paid or not, never submit and never pay; if the clinic is already listed, ask the publisher in writing to remove it, and check on the due date. For every paid slot, first ask how it is billed; if you can't get a clear answer, don't do it. For anything priced per lead or by commission, don't do it until you have the compliance officer's written confirmation.

Labelling it "paid listing" is not a shield: the regulator has specifically answered whether a paid review is allowed once the sponsorship is disclosed, and the answer is no (Statute text; see Appendix A.1). Disclosing payment deals with honesty, not with the regulation.

Each item in the left column has its own basis: technical SEO and structured data are not advertising in themselves; a pure directory listing that contains only contact details, is ordered alphabetically by name or in another sequence, and does not highlight any one business is exempt (a paid "featured" or "top" slot is not covered by the exemption); a factual entry on a permitted medium is allowed as long as all of its content is compliant; on a platform that uses patient ratings, whatever you put up counts as advertising, so don't join it (all Statute text; see Appendix A.1, A.2). A list whose title carries a laudatory term hits a different rule: laudatory terms are banned outright, regardless of whether they are true (Statute text; see Appendix A.1). A third party's list of clinics that have been accorded an honour is itself advertising; once the clinic knows about it, what the MOH FAQ asks for is reasonable steps to get the publisher to remove it, then a check that it was removed properly, not a correction (Statute text; see Appendix A.1). So this kind of page gets no correction letter — correcting one sentence on it amounts to supplying material — only a removal request, worded as in Appendix B.2; treating "best N clinics" editorial blog posts as this kind of advertisement too is this book's reading (Conservative line (not statute text)).

When a third party puts the clinic on a list entirely on its own initiative, the clinic is not liable. The moment you supply copy, give material or pay, it is no longer "entirely on its own initiative", and under this book's reading that protection is lost at once (Conservative line (not statute text); the original wording of that condition, "acting on its own accord", is in Appendix A.1).

A pure directory and a price-comparison page are not the same thing, so don't budget for them as equals. A price-comparison page is Group A, done in passing. A pure directory is a Group C logging action, done only when it's free or very cheap and can be finished in passing; it takes no person-hours from the budget and gets no enquiry letter (the citation-density gap between the two comes from deltaV's per-page-type statistics).

If you genuinely need a platform priced per lead or by commission, first get the compliance officer to confirm in writing that it is not fee-sharing; the arrangement must also never appear in any advertisement. Only the client and the platform know how it is billed, so this is the first of the three stop-and-escalate situations in 1.1.

43.8% of ChatGPT citations come from best-of blog posts. That is a share figure, and it does not carry over to dental: in healthcare, listicles made up a measured 0% of citations, and in dental all you can do with a Best / Top page is request removal anyway. Each of these two reasons stands on its own; neither may be used in place of the other (the 0% for healthcare comes from deltaV's per-industry page-type statistics; for why the two figures must not sit side by side in the same table, see → General Edition 6.1 Where the effort goes, and two numbers that must not sit side by side). Don't submit to, or buy a slot on, a page with Best or Top in its title just to pad out Group A; the number of Group A entries is never a threshold for any verdict.

Mark every paid entry "paid listing" line by line in every task and every monthly report, with its cost listed separately; never write it as "recommended" or "included in an independent review". The general spec is in → General Edition 6.2 The send gate, paid listings and the citation-slot table.

6.3 The four Group B steps and Singapore dental and aesthetics sources

What you'll do in this section: First finish the four Group B steps in order, without skipping a single free item. Then judge each candidate site one by one. The compliance verdict always comes before priority: a site judged "request removal", "correction only" or "do not do" gets no submission letter, however high its priority.

The order of the four Group B steps must not be reshuffled; don't touch Group A submissions until every free item is done. Leave even one free item blank and this quarter's off-site work does not count as finished. Don't treat Group B as "cheap, so do it in passing": most of it is free, stays in place once done, doesn't depend on a third-party editor saying yes, and it is the group whose share is rising: institutional and government sources have risen from about 1/6 to close to 1/3 of ChatGPT citations (Otterly / Axios public tracking, 2026-08).

One manufacturer-locator application pays off twice: a Group B inbound link, and a third-party endorsement of the real brand and model of the device. Do this only for brands you actually use. "Platform-managed" containers such as the five business profiles and manufacturer locators are the cell most often missed entirely, and the cost of misjudging them is medium. They are already built into steps 1 and 4 of the figure above, so if you follow it you won't miss them. The compliance scope of the five business profiles themselves is covered in 3.4 and not repeated here.

Group A is a structural gap in Singapore: almost every local third-party price-comparison page carries Best or Top in its title, so the verdict is no submissions, and request removal where the clinic is listed. Don't wait for a Group A list to build up before you start; it never will. Build your own all-products price guide page instead, and keep off-site Group A to opportunistic slots only.

The type, contact details, billing method and compliance verdict for 10 dental sites and 10 aesthetic sites are in Appendix B.1. For each site, that table is what counts; the decision figure above only shows you how to judge one.

You can't build a register yourself, but get into every one you can. Use the self-supplied blurb that a register page allows to state how you charge and what your credentials are: it is the lawful way to put your own sentences onto an authoritative domain. The blurb, too, gives only fixed final prices, with no "From", no discount and no "best". Fill in the entry title as a three-part string: English name • Chinese name • category and location. Leave a field blank and it's the same as not being listed — that row is exactly what AI copies.

The only citable official credential is your own licence/registration number plus a link to the official lookup page; never cite any third-party register that calls itself "MOH-verified" or "government-recognised", and don't list on it either (banned list in 1.5) [Conservative line (not statute text)]. Off-site assets decay; run the monthly review per → General Edition 6.6 Annual rankings and off-site asset decay.

6.4 Doctor-bylined contributions, outreach letters and supplying price material directly

What you'll do in this section: Treat bylined contributions as top priority (P0): under the doctor's own name, giving checkable facts that only this clinic has. Open every outreach letter by stating which five things you will not supply. Supply the price table straight to third parties, matching your website line for line, and send an update letter the same day a price changes.

In healthcare, articles (article) make up 54% of cited content (from deltaV's per-industry page-type statistics), which is why bylined contributions are P0. Start in weeks 2–3. Targets: local news, professional media, association newsletters, and the practitioner directories and educational columns of government and statutory bodies. The byline must be the doctor's own, linking back to their person page. In the figure, the three byline items and the ban on sentences that solicit appointments come straight from the SDC ECEG, which says a dental practitioner must ensure that he/she "does not solicit or encourage the public to seek consultation or treatment", and "Only the dental practitioner's name, registered field of practice and place of practice may be mentioned in such instances" (Statute text; see Appendix A.2).

Send the outreach letter as the main letter in → General Edition B.3 Outreach emails and review replies. Dental adds only two things: one line stating your licensed status and registration number, and one paragraph declaring what you will not supply: testimonials, success rates, before-and-after photos, peer comparisons, and laudatory terms such as "best / preferred / leading", including in the title of the page carrying the entry or in the list's name. Put the declaration near the top of the letter, so the other side knows the limits before drafting anything. The full Chinese and English text and the insertion point are in Appendix B.2.

Supplying price material directly: the day the price page goes live, attach the public version of the same table and send it straight to price-comparison articles, directory price columns and price-guide sites. It costs almost nothing. The table you send out gives only fixed final prices, tiered and itemised, with no "From", no range, no original price and no percentage change, and it matches the price page on your website line for line. The day a price changes, send an update letter to every place that has carried the table: an old price left in a third-party profile gets quoted by AI as the current one.

6.5 Reviews: never ask, never repost; only reply and add facts

What you'll do in this section: Do only two things with reviews: when a patient leaves a review on their own initiative, reply within 72 hours using a template that doesn't confirm who they are; and fill in every fact field in the five business profiles. Take zero actions that ask for reviews. Fill the slot that reviews leave empty with the four substitutes below.

For dental, read only the strictly regulated column of the figure above.

Red line: never request reviews, never send a review-request template, never set a KPI on review count, never prompt a patient to leave a review over WhatsApp, SMS or email; never repost any review's original text, screenshot, star rating or aggregateRating on your website, social media or promotional material. The party publishing on the client's behalf is jointly liable with the licensed institution (Statute text; see Appendix A.1, A.2); the penalty is a fine of up to S$20,000, up to 12 months' imprisonment, or both, plus up to S$1,000 a day for a continuing offence (Statute text, HCSA s 31(3); see Appendix A.1).

In the monthly report, review counts and star ratings are recorded only as passive observation, never entered as a task metric or an acceptance measure (the monthly report's fixed sentence is in Appendix B.3). The alternative outlets are registration status, technical-standard certification and checkable-fact sentences (see 3.3). In dental, the substitute for asking for reviews at scale is to use checkable-fact sentences (licence number, device model, procedure duration, insurance coverage) to take the same extraction slot.

Replying to reviews: the regulations themselves do not say how to reply (Original text not obtained), so write on the most conservative basis and keep the template on file (template in Appendix B.2). The template does not confirm that the reviewer is a patient of the clinic and does not restate the treatment they received. Publicly confirming either one counts as disclosing sensitive health data without consent and breaches the medical confidentiality obligation (Conservative line (not statute text); source in Appendix A.3). A patient writing it themselves in a review does not give the clinic authorisation to confirm it publicly.

How to read the four substitutes: for item 3, write only registration status and technical-standard certification — never a manufacturer-granted tier (the conservative line, see 3.3).

Item 2, institution-bylined medical educational long-form content, is not yet decided. For now the execution layer does not add it, spends no person-hours on it and gives it no slot in the site schedule; this does not stop off-site bylined contributions (6.4) from going ahead. A pure directory listing with no laudatory wording doesn't count among the four: it is the page type with the lowest citation density and is only a logging action (see 6.2). The column headers for the three monthly review numbers are in → General Edition B.4 Headers for work orders, ledgers and monthly reports.

6.6 Annual rankings and long videos narrated by the doctor

What you'll do in this section: Don't go looking for a "Best Dentists"-type list: we checked, and there isn't one. The one you can go for is the revenue-growth ranking, rechecked once a quarter. If you are selected, the compliance officer decides first whether and how the website mentions it; until then, the website says nothing. Within 14 days of each thick page going live, add a long video narrated by the doctor, covering only the procedure, the devices, the cost breakdown and the indications.

We found only two ST × Statista rankings for Singapore: Best Employers and Fastest-Growing Companies (a revenue-growth ranking that requires submitting financial data). There is no Best Dentists / Best Doctors. The only one open to dental and aesthetics is the latter (80% confidence); recheck the SG entries on rankings.statista.com once a quarter. Even if you are selected, whether the website carries this sentence is a stop-and-escalate item: take it to the compliance officer first. In other industries the wording is a bare factual statement plus a link to the original ranking, with no "best" and no adjectives. Here that collides with two other rules: the clinic's own pages do not quote any ranking (Statute text, Reg 13, Reg 5(1)(e); see 0.3 and Appendix A.1), and outbound links never go to a commercial company (Statute text; see 1.5 and Appendix A.2). Until it is decided, the website says nothing; just log the ranking page's URL in the citation-slot table and use it as an off-site entity signal.

The video script is the thick page's H2 questions, spoken one by one, one segment per H2, adding no fact that isn't on the page (every fact comes from the fact table). The transcript is public text, so it is advertising too: it goes through the banned-word list in the same process, with the same signatory, as the thick page. Being a video does not lower the bar. The video spec, acceptance criteria and the correlation evidence behind it are in → General Edition 6.7 Long videos narrated by the named expert; dental only adds this one compliance gate.