OPS-SOP-016 — Ad Creative Review & Legal Approval (Tessa Workflow)
1. Purpose
This SOP governs the mandatory compliance review and approval of all Unity Care Solutions marketing and advertising materials before publication. All materials — without exception — must be reviewed and approved by Tessa (internal compliance) before being published, run as ads, or distributed in any channel. This process protects Unity from regulatory exposure related to self-funded plan advertising, HIPAA-compliant targeting, and accurate representation of benefits.
2. Scope
Applies to all Unity Care Solutions marketing and advertising materials, including:
- Facebook and Instagram paid ads (all formats: image, video, carousel, lead forms)
- Landing pages and web copy related to plan benefits or enrollment
- Email marketing campaigns (to employers, employees, or brokers)
- Social media organic content (Unity brand accounts)
- SMS/text campaigns
- Broker-facing materials (sell sheets, one-pagers, presentations)
- Dash Activate creatives (~50 creatives/month — same process applies)
- Any edits to previously approved materials that change substantive language, benefit claims, or targeting parameters
Dash Activate: Due to high volume (~50 creatives/month), Dash Activate submissions should be batched and submitted to Tessa in groups where possible. Each creative in the batch must be individually reviewed and approved before launch. Batch submissions do not reduce the review standard.
3. What Triggers a New Review
A compliance review with Tessa is required for:
- Any new creative — including new ad copy, new visuals with text, new landing page, new email template
- Any material edit to existing approved creative — including changes to: benefit language, coverage claims, pricing statements, DPC/self-funded framing, disclaimers, call-to-action language, or targeting criteria
- Repurposing approved content for a new channel — e.g., taking an approved email campaign and running it as a Facebook ad requires a new review
- Seasonal or promotional variations of existing creative that modify substantive language
Does NOT require a new review: Minor formatting changes (font size, image crop, color adjustments) that do not alter substantive language or benefit claims — provided all other elements of the approved creative are unchanged. When in doubt, submit for review.
4. What Tessa Reviews
| Review Area |
What Tessa Checks |
| Regulatory Language |
Required disclaimers present; language complies with applicable insurance, ERISA, and advertising regulations; no misleading statements about coverage, cost, or enrollment eligibility |
| Self-Funded Plan Claims |
Benefits described accurately per plan document; no promises of coverage not in the plan; appropriate language distinguishing self-funded plan from fully-insured products |
| DPC Framing |
Direct Primary Care benefits framed accurately; DPC is not described as insurance; scope of DPC services matches actual program; no implication that DPC replaces comprehensive coverage |
| HIPAA Compliance in Targeting |
Ad targeting parameters do not use PHI or prohibited health-condition targeting; custom audience data sourced appropriately; lookalike audiences do not derive from PHI sources |
| General Accuracy |
Cost figures, employer contribution examples, and savings claims are accurate and supported; testimonials comply with FTC guidelines; no unsubstantiated superlatives |
5. Submission & Review Process
Zero exceptions. No Unity marketing material may be published, scheduled, or launched without Tessa's documented approval. This includes urgent, last-minute, and "just a quick" changes.
Step 1 — Submit Sales/Marketing prepares the creative and submits it to Tessa via the designated compliance chat thread. Always use the same thread — do not open new threads with Tessa for ad review. Submission must include: (a) the creative file(s) or link, (b) the intended channel(s), (c) the intended audience/targeting description, and (d) the requested launch date.
Step 2 — Tessa Reviews Tessa reviews the submission. Standard turnaround is within 24 hours of submission (business days). If Tessa needs additional context or a source document, she will request it via the same thread — the submitter must respond same day.
Step 3 — Decision Tessa issues one of three outcomes:
- Approved — No Changes: Creative is cleared as-is. Log approval and proceed to launch.
- Approved with Edits: Tessa provides specific required changes. Make edits, confirm in thread that changes are applied, and receive final confirmation before launch.
- Rejected with Notes: Creative cannot be used in current form. Tessa provides notes on required revisions. Revise and resubmit as a new submission in the same thread.
Step 4 — Log Approval Upon final approval, the submitter logs the approval in the Creative Compliance Log (see Section 6). Log entry must include: creative name/ID, channel, submission date, approval date, outcome, and Tessa's confirmation (screenshot or message reference).
Step 5 — Publish Creative may be published, scheduled, or launched only after the log entry is complete. If publishing is handled by an external party (e.g., Dash Activate), forward approval confirmation to that party before authorizing launch.
6. Creative Compliance Log
A running log of all submitted and approved creatives is maintained by Marketing/Operations. The log must be updated within 24 hours of each approval decision.
| Field |
Description |
| Creative ID / Name |
Unique identifier or descriptive name of the creative |
| Channel |
Facebook, Instagram, Email, Landing Page, LinkedIn, etc. |
| Submitted By |
Team member who submitted for review |
| Submission Date |
Date submitted to Tessa |
| Approval Date |
Date final approval received |
| Outcome |
Approved / Approved with Edits / Rejected |
| Notes |
Any required edits or rejection reasons |
| Approval Reference |
Link or screenshot of Tessa's approval in chat |
| Launch Date |
Date material was published or launched |
7. Escalation
- If Tessa does not respond within 24 hours, Operations must follow up via the same thread.
- If turnaround cannot meet a critical launch deadline, Operations escalates to leadership to make a go/no-go decision — the default is always no launch without approval.
- Any creative run without Tessa's approval must be immediately pulled and reported to Operations. The incident must be documented and a corrective action logged.
8. Related Documents
- OPS-SOP-017 — Content Publishing & Compliance Sign-Off
- Creative Compliance Log [link TBD]