The monthly figure is the problem
Almost every disclosure failure in this area reduces to one pattern: a prominent monthly figure and a much less prominent total. A treatment presented as a small weekly amount reads as an inexpensive decision, and the arithmetic that would correct the impression is placed where it will not be read.
This matters more in an elective clinical context than in retail, because the decision being influenced is a decision about a procedure. A patient who would not have proceeded at the stated price, but proceeds at the monthly figure, has had the cost barrier removed by presentation rather than by any change in what they will pay. Where that interacts with a consent process designed to give people time to reflect, the two are pulling in opposite directions.
The criteria here are therefore weighted towards prominence and towards consequences. Total repayable, rate, provider, eligibility, and what happens when things go wrong. None of this is onerous to state and stating it changes how the offer reads.
Criterion ten deserves particular attention. Depending on the clinic's role in arranging credit, authorisation may be required, and the position is not obvious from the outside. The FCA's consumer credit material is the starting point, and clinics should establish their position rather than assume the provider has handled it.
How to score this checklist
Collect every surface on which finance appears: website pages, price list, social posts, in-clinic posters, email templates and anything a patient is handed. Score by the weakest surface.
For criterion one, look at relative prominence rather than presence. If the monthly figure is in a larger size, a brighter colour or a more prominent position than the total, score 0. This is the criterion that fails most often and it fails visually rather than textually.
For criteria four to six, ask whether a patient could answer three questions from your material alone: will I be credit checked, what happens if I am declined, and what happens if I miss a payment. If any answer requires opening the provider's terms, score 1 at most.
For criterion nine, ask two members of staff to explain the finance offer as they would to a patient, and compare with the published material. Differences are common and usually consist of confident statements about eligibility that nobody at the clinic can actually make.
For criterion ten, ask what the clinic's role is in the arrangement and what the answer implies. Uncertainty scores 0.
Common scoring errors
Treating a link to the provider's terms as disclosure. The criteria ask what the patient can establish from your material.
Scoring prominence by presence. Both figures appearing on the page is not equal prominence.
Presenting interest free as though it had no consequences. Interest free arrangements still have missed payment consequences and still involve a credit agreement.
Bundling the credit decision with the treatment decision. Offering finance at the moment of clinical decision makes the two feel like one choice. Criterion seven scores whether the separation is explicit.
Applying an expiry to a finance offer. An expiring finance offer is a pressure device applied to a credit decision and scores 0 on criterion eight.
Presenting finance without pressure
The version of this that works is unremarkable. Finance appears as one of several payment options, with the total, the rate and the provider stated alongside the monthly figure at the same visual weight. It is mentioned once in the consultation summary rather than raised repeatedly. It carries no expiry.
Separate the conversations in time where possible. A patient who has decided on a treatment and then considers how to pay for it is making two decisions. A patient offered a monthly figure while deciding whether to proceed is making one, and it is not the one the consent process assumes.
Script the staff conversation and keep the script with the published material so the two stay aligned. The commonest inconsistency is staff offering reassurance about approval that neither they nor the clinic can give.
Include finance material in the advertising approval process covered by the advertising compliance self-audit, since finance posts are frequently produced quickly and reviewed least. Where deposits interact with finance, the pricing transparency scorecard covers the deposit terms that should be stated alongside.