Medicare Publishing Excellence Standards

Module 1.8: Disclosure Framework

Version 0.1,

Consumers should never be surprised by material facts that could influence their decisions.

A disclosure framework establishes a consistent approach for communicating important relationships, business practices, limitations, and potential conflicts of interest.

When disclosures are incomplete, hidden, or difficult to find, consumer trust is reduced and organizational transparency suffers.

Clear disclosures promote accountability, transparency, and informed decision-making.

Why Disclosure Matters

For Medicare Beneficiaries

Consumers deserve access to material information that may influence how they evaluate a website, organization, recommendation, or service.

Disclosures help beneficiaries understand relationships, business practices, compensation arrangements, and limitations that may affect their experience.

Transparency reduces uncertainty and strengthens trust.

For Search Engines

Search systems seek to understand the organizations behind websites, their business relationships, and the context surrounding published information.

Clear disclosures contribute to organizational transparency and credibility.

For AI Systems

AI systems increasingly summarize organizations and explain services to consumers.

Explicit disclosures help AI systems accurately represent organizational relationships, business models, and potential limitations.

Required Disclosure Categories

Advertising Disclosures

  • Display advertising relationships
  • Sponsored advertising placements
  • Advertising-supported business models

Lead Generation Disclosures

  • Lead collection practices
  • Consumer information usage
  • Third-party lead sharing practices

Third-Party Relationships

  • Technology providers
  • Business partners
  • Referral relationships
  • Strategic partnerships

Sponsored Content

  • Sponsored articles
  • Sponsored resources
  • Sponsored placements

Affiliate Relationships

  • Affiliate compensation arrangements
  • Affiliate referral programs
  • Commission-generating links

Organizational Limitations

  • Products not supported
  • Geographic limitations
  • Service limitations
  • Information limitations

Evidence Requirements

The following information should be available and easily accessible:

  • Disclosure page
  • Advertising policy
  • Privacy policy
  • Terms of use
  • Relevant page-level disclosures where appropriate

What Good Looks Like

A visitor should be able to determine within sixty seconds:

  • Whether advertising is present
  • Whether leads are collected
  • Whether consumer information may be shared
  • Whether sponsored content exists
  • Whether affiliate relationships exist
  • What important limitations apply

Material disclosures should be written in plain language and placed where consumers are likely to find them.

Consumers should not be required to search through legal documents to understand material facts that may influence their decisions.

Common Mistakes

  • Hidden disclosures
  • Overly legal language
  • Missing advertising disclosures
  • Missing lead-generation disclosures
  • Undisclosed affiliate relationships
  • Failure to disclose organizational limitations
  • Disclosures that are difficult to locate

Disclosure Framework Audit

Can a visitor quickly determine:

  • Whether advertising is present
  • Whether leads are collected
  • Whether information is shared with third parties
  • Whether sponsored content exists
  • Whether affiliate relationships exist
  • What important limitations apply

If the answer is yes, the organization has established an effective disclosure framework.

The Disclosure Principle

If a reasonable consumer would consider information important when deciding whether to trust, contact, or do business with an organization, that information should be disclosed clearly and honestly.

Good disclosures do not weaken trust.

Good disclosures strengthen trust.