CareDash -- Disturbing Practice
CareDash acts as a healthcare review website for a wide variety of providers, including clinical social workers, providing information on patient reviews, disciplinary actions and other issues. According to its website, CareDash “is a solution for patients looking for transparent and trustworthy information about healthcare providers, practices and hospitals in their area.”
As many of you already know, CareDash has created and posted on its website profiles of thousands of clinical social workers around the country -- without their knowledge or consent. (The profiles are created from public records, including NPI records.) It has done so for the purpose of driving prospective clients of these therapists to CareDash for referrals to other therapists who are participating providers with CareDash itself for referrals to its participating therapists.
The process works as follows: when searching for a specific therapist on CareDash.com, after selecting that therapist and clicking on “check availability,” the website automatically provides the prospective client with the following message: “[The desired therapist] has not provided a way to schedule online through CareDash. However, you could get connected with an online therapist or chat with our virtual assistant to get help finding a therapist.”
Just below that message, the prospective client is offered the option to select from one or more alternative therapists – who participate with either CareDash. Or, the individual may choose to chat with CareDash’s virtual assistant. The website notes that CareDash may receive commissions when the consumer chooses one of these providers.
This practice has multiple harmful effects on both the therapist and prospective client. For details, see the description of concerns in the discussion below on filing a complaint. Although public information on therapists is used in creating the profiles, this appears to be an improper deceptive practice. It potentially violates federal and/or state consumer protection laws.
Filing a Complaint
Overview
If CareDash has created a profile of you and posted it on their website without your consent, we suggest you consider filing a complaint with the consumer protection division of the state attorney general’s office. Click here to find the link to the state’s office and its complaint form. You may also choose to file a complaint with the Federal Trade Commission. (It is your choice whether to file with only one or with both of these agencies.) The FTC’s complaint form can be found here.
Both the state attorney general and the FTC are authorized to investigate apparent scams and deceptive business practices such as this one, pursue a voluntary resolution and, if necessary, bring enforcement cases.
Note that it is not entirely clear whether this practice violates state or federal law, although NASW believes it likely does. Even if the practice is illegal, there is no guarantee that either of these agencies will investigate a complaint or ultimately require CareDash to discontinue the practice.
However, the more complaints filed, the greater the likelihood that these agencies will act. Please review the state attorney general website for more information on its authority and complaint process; for more information on the FTC’s authority and complaint process, see their FAQs.
Again, you should only file a complaint if CareDash has posted your profile without your consent. Please go to www.CareDash.com to confirm whether that is the case. If so, you should note any inaccurate information contained in the profile and the improper posting of personal information (such as home address or phone number); these points can be included in your complaint.
What to Include in Your Complaint
The following information may be included in both your state attorney general and FTC complaints (note that when starting to complete the FTC’s complaint form, one is prompted to choose a problem category; we suggest you select “Health” and the subcategory “Any other health care problem”):
Name of companies to complain about – CareDash. Note that the FTC form allows only a reference to one company; include only CareDash for the FTC complaint.
Companies’ location: CareDash’s corporate office address is: 614 Massachusetts Ave., Ste 400, Cambridge, MA 02139.
Prior attempt(s) to resolve the issue: If this information is requested in the complaint form, indicate whether you have called or emailed either company to complain about this practice, provide the date of the contact(s) and describe your efforts. Also note the identity of the representative with whom you communicated and the date and a description of any response provided.
Description of the practice and concerns: the following is a general description of the practice and its impact – feel free to use this a guide, modifying the description in your own words, as appropriate (of course, only include the statements noted below that apply to you personally):
CareDash, a healthcare provider review website, has created and posted on its website my profile as a therapist. It has done so without my knowledge or consent. I believe the purpose of this posting is to drive my prospective clients to CareDash, an online therapy platform, for referrals to other therapists who have agreed to participate with CareDash, or to therapists who participate with CareDash itself. I am not a participating provider with CareDash; therefore, it is impossible to seek my services through these providers.
The process works as follows: when searching for a specific therapist on CareDash.com, after selecting that therapist and clicking on “check availability,” the website automatically provides the prospective client with the following message: “[The desired therapist] has not provided a way to schedule online through CareDash. However, you could get connected with an online therapist or chat with our virtual assistant to get help finding a therapist.”
Just below that message, the prospective client is offered the option to select from one or more alternative therapists – who participate with CareDash. Or, the client may choose to chat with CareDash’s virtual assistant. If choosing the virtual assistant option, the prospective client is automatically directed to a page where a selection of only their participating providers is available. The website notes that CareDash may receive commissions when a consumer chooses one of these providers.
This practice misleads or deceives individuals who may be seeking to engage me as a therapist. That is, CareDash is falsely marketing my services to generate online traffic for itself, ultimately resulting in the selection of participating providers, rather than me.
CareDash’s diversion of my prospective clients in this way interferes with my business. This amounts to a misappropriation of my name and reputation for commercial gain.
Additionally, the practice harms the direct consumer of therapy services: a client who is seeking my services is the victim of a bait and switch scheme. In being diverted to CareDash providers, they may be routed to a provider who cannot meet their needs.
[INCLUDE THE FOLLOWING PARAGRAPH ONLY IF IT APPLIES TO YOU]
"Further, the posted profile is incomplete and contains erroneous information, misrepresenting my practice areas. It also contains personal information. I am very concerned about this misrepresentation because it misleads potential clients and may implicate my ethical duties as a licensed therapist."
CareDash’s website (see last FAQ for Doctors) states that it will not take down postings of providers. Specifically, they say, “Because the information listed on CareDash profiles is of interest to the general public, CareDash’s policy is that we do not, under any circumstance, remove a profile.” Accordingly, I do not have this option available to address my concerns.
I understand this practice extends to other types of mental health care providers, including psychologists.
Thank you for your attention to this matter. I look forward to hearing from you.
UPDATE: 8.15.2022
As noted in the blog, BetterHelp has disassociated itself from CareDash and is no longer promoted by them, and CareDash has otherwise modified its practices, although we still have concerns
We previously informed you of our concerns about the posting of psychotherapists’ profiles, without their knowledge or consent, in soliciting business for online psychotherapy platforms. We are happy to report that – with the help our members – significant progress has been made in addressing these concerns. For a summary of developments, see this NASW blog.
Given this progress and ongoing discussions between NASW’s National Office and CareDash and BetterHelp, we ask that you refrain (at least temporarily) from filing complaints on this issue with law enforcement/consumer protection agencies, including the state attorney general and the FTC.
We will continue to update you on developments as they occur.
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