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- #58: From Access to Accountability
#58: From Access to Accountability
How trust is shifting and the opportunities that creates
Hi friends,
The nature of trust in mental health is changing.
It used to be a one-to-one relationship. Clients trusted their clinician to make them better.
But as mental health platforms have gained traction, the nature of that trust has shifted. These platforms intermediated the relationship. Many clients now place their trust in these businesses, and that has created both challenges and opportunities.
While this has been developing, the requirements for trust have been changing too. Providing access to services is no longer enough - clients are demanding more. At times, trust has cracked when businesses messed up, and clinicians are questioning which organisations are deserving of their time and effort.
The future of mental healthcare will be shaped by those who understand these shifts in trust and the opportunities they provide. That’s what we get into in this week’s edition of The Hemingway Report.
To explore this topic, I’ve been working with Bethany Pfohl. Bethany is a brand and marketing strategist with roots in health and wellness. She thinks deeply about how organisations clarify their voice, connect with people, and grow with intention. She has recently turned her focus to digital mental health, so I thought having her as a co-author would add an experienced and fresh perspective to the piece. I think you’ll find that was the case.
Alrighty then…
Let’s get into it!
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1. Access, Trust and Intermediation
Things were different before 2020. If you asked someone who they went to for mental healthcare, they’d give you the name of their therapist. Today, many will give you the name of a mental health business.
How did this happen?
Well, we had this thing called COVID. Offices closed, schools went remote, and grocery shelves emptied. As people struggled to adapt to a world of isolation, demand for mental healthcare surged. And that demand needed to be delivered virtually.
Digital platforms offered a great solution. Existing players expanded and raised money to support their growth. Many new startups also sprang up to meet this demand.
The solution was compelling and based on a simple promise. Access.
If we look back at how these businesses were marketing themselves at the time, we can see how central “access” was to their value proposition.

A collage of COVID era messaging from mental health businesses.
Talkspace focused on reach and visibility, pairing Michael Phelps with messaging about coverage through health plans and workplace benefits. Demi Lovato added emotional weight, encouraging people to seek help when they needed it.
Talkspace messaging from August 2020
BetterHelp centred on ubiquity, becoming the top podcast advertiser in the country, with hosts and creators folding the brand into casual scripts and daily routines. On TikTok, therapy sessions took place in bedrooms, cars, and quiet corners between shifts, reinforcing the idea that care was always close by.
BetterHelp messaging from August 2020
Cerebral emphasised speed, promising fast access to therapy and prescriptions through a streamlined experience that highlighted affordability and simplicity. Social campaigns focused on removing barriers and helping people get started quickly.
Cerebral messaging from September 2020
People needed access, and they trusted these businesses to give it to them. This trust facilitated the intermediation of the mental healthcare industry.
2. The Nature of Intermediation
As mental health platforms gained traction, they introduced a new layer between client and clinician. Algorithms made the match, apps conducted intake, and sessions took place virtually, through branded interfaces. This added a second, more abstract relationship - trust in the platform delivering the care, trust in mental health businesses themselves.
This presented a huge opportunity for platforms. If they could own the relationship with clients, they could own the pipeline of therapy sessions. Clinicians would then need to join their platform in order to get work. This would give them significant power in the market. Power, which, over time, could also be used to reroute clients into more profitable treatments (like digitally delivered content, digital therapeutics, etc.).
Now, don’t mistake my view on this intermediation as cynical or negative. Intermediation like this is not necessarily a bad thing. In fact, it can be quite positive.
We have seen this play out in other industries, where platforms and marketplaces intermediated individual providers; Airbnb, Uber, and even industries like banking. Although my Dad still laments his lost relationship with his bank manager, the experience of banking is objectively much better than it used to be.
There can be many benefits to intermediation.
In mental health, access did improve. Instead of having to find and vet individual clinicians, clients could just sign up to a platform and know they could get care quickly and easily. Platforms simplified processes and provided more integrated care with greater flexibility and continuity. They offered new digital interventions that genuinely helped millions of people.
Clients now had relationships with these businesses. But clinicians did too. Many chose to work with these platforms, out of choice or necessity, and they had to determine which platforms they trusted and wanted to work for. Without clinicians, these businesses have no service to offer, and so, trust amongst clinicians was also incredibly important.
To summarise where we’ve got to so far… The potential of mental health platforms is based on intermediation. Intermediation requires trust. Trust was established by providing access.
But over the last five years, the actions of certain players have put that trust at risk.
3. Cracks in the Foundation
"It takes 20 years to build a reputation and five minutes to ruin it."
Some platforms became intoxicated with the levels of demand for access. The temptation of growth was too much to ignore, and some organisations made mistakes; mistakes that prioritised growth and revenue over trust. That was a critical error.
From 2021 through 2025, a steady stream of legal and regulatory actions raised concerns around how care was being delivered, marketed, and protected by mental health businesses. On top of lawsuits, federal agencies issued fines, ordered consumer refunds, and placed new limits on how companies engage with and handle user data. Around the same time, studies flagged that roughly 60% of apps raised privacy concerns or made unsupported claims. In parallel, lawmakers began pushing for stronger standards.
The cases that followed didn’t (and still don’t) define the industry. Many organisations continued their work with rigour and diligence. But the events did impact how digital mental health was being evaluated as a collective whole. And they damaged trust.

Legal & regulatory action taken against mental health businesses since 2025 (non-exhaustive)
I believe deeply in the potential for mental health businesses to improve population mental health. But, as I said in a recent LinkedIn post, we need to “stop fucking up”. Each of these cases doesn’t just damage trust in the organisation at fault, but the industry as a whole (even those who haven’t done anything wrong). If clients and clinicians lose trust in mental health businesses, their role in the ecosystem is at serious risk.
An intermediation strategy without trust from both sides of the equation won’t endure.
4. New expectations for trust
Yes, the strength and potential of mental health businesses depend on trust, and as we’ve seen, that trust is at risk. But this is not just because of bad actions from a few businesses; it is also because the expectations for trust, amongst clients and clinicians, are changing. You might have noticed this already.
Clients are becoming more discerning. Clients used to be happy just getting access to services. Now, they demand much more.
They are more informed. Many understand more about mental health, diagnosis and treatment than they did five years ago. They often come to their first session knowing the kind of treatment they want.
They are more concerned with ROI. Payers aren’t the only ones concerned about ROI. Budgets are tighter than they were five years ago, and treatment remains expensive. People are increasingly questioning the ROI of their mental healthcare.
Some are disenfranchised. Some people feel fed up with mental healthcare. They did what they were told they needed to do: “ask for help”. But when they did, they went into care that often didn’t make them better. They’ve been on medication and in therapy for years, but still feel the same. Of course, the unfortunate reality is that even in the best care, this can happen. But either way, these people have often lost trust and hope in the mental health system. Some have received poor care through budget-priced mental health platforms. Some have just had bad therapists from good businesses. Either way, these stories are spreading, and those platforms are losing clients.
A new kind of cynicism is taking root. While overall stigma continues to reduce, I’ve noticed new pockets of stigma and “mental health denial” begin to emerge. I’ve seen several influencers (mostly male) deny the existence of mental disorders. They claim that companies are incentivised to give you a diagnosis and keep you in therapy, and as a result, are not acting in your best interests. This stuff makes me so angry. But we must realise that many people listen to and believe these influencers.
Clinicians are pushing back. Tension between clinicians and platforms is high. Trust is challenged - I’ve written about this extensively. Many clinicians say they are expected to deliver care without having a voice in how that care is structured, evaluated, or compensated. Across the field, concerns about workload, pay models, compensation levels and whether current systems allow for the kind of care they were trained to provide are openly expressed. One group bringing that perspective forward is Therapy Trust Collective, a clinician-led organisation advocating for more collaborative, transparent models of care. On LinkedIn, they wrote;
“Clinicians should have a seat at the table when decisions are being made about the companies shaping our field… We want to ensure mental health companies succeed in practice, not just in theory.”
Clinicians want to be more involved in defining what comes next, for themselves and their patients. Scandals like we’ve seen over the past five years damage the trust between clinicians and platforms.
Employers and payers are tightening standards. After years of expanding mental health coverage, many buyers are now under pressure to justify rising costs and show meaningful results. Despite significant investments, mental health outcomes have not improved. A Business Group on Health 2024 survey found that nearly every large employer plans to hold vendors to higher standards. Usage and enrollment alone no longer carry as much weight. Buyers are trying to assess whether care is helping people feel better, stay productive, and avoid higher-cost services down the line. When those signals aren’t clear, contracts are being reevaluated.
5. A Trust Crossroads
Without trust, mental health platforms have no power in the market. We’re at a crossroads. The actions these businesses take over the next few years will determine if they can justify and maintain their role as an intermediary, or whether client and clinician distrust will drive them to obsolescence.
Building trust through accountability, clarity and outcomes
Mental health businesses must move past a promise of access to a promise of accountability. Accountability to provide high-quality care that delivers clinical outcomes. Care that helps people live healthier, happier lives, and does so at appropriate costs. This also means accountability to treat clinicians fairly, to compensate them well and to involve them in leadership.
Creating Clarity
If you’ve read my reports for long enough, you’ll have heard me bang on about the opportunity of being a high-quality provider. Not only because it’s necessary to preserve the trust required for intermediation. But because it will allow businesses to create differentiation in a competitive and largely commoditised market.
But there’s a marketing challenge with being a high-quality provider. How do you communicate your quality to stakeholders, especially to clients? Mental healthcare is a complex and opaque system. As a lay person, it’s hard to know what good mental health care looks like, let alone which organisations provide it.
Most people will start their journey with a Google search, often comparing providers. This will lead them to media outlets like Forbes, Wirecutter, and CNET offering ranked lists of different platforms, focused on cost, convenience, and their app experience. They're helpful to a point, but rarely explain how care is delivered, measured or what kind of safeguards are in place. Clinical standards and actual outcomes are hardly ever mentioned.
Professional groups have tried to close that gap. In the APA’s App Evaluation Model, clinicians are given a rating system and rubric across five defined measures to evaluate whether an app is appropriate for a particular patient and situation. But those guidelines tend to stay within professional circles.
So people do their best with what they have. They ask around. They Google. But when they can’t get good answers on quality, they often settle for those services that are easiest to access (even if this means using tools like ChatGPT).
The opportunity here is not just to become the high-quality provider in the market, but to create the standards and messaging that make this understandable to normal people. To give them clarity on what high-quality mental healthcare is and to help them understand why they should trust you.
A Diamonds is Forever
The diamond company De Beers offer a great example of this.
Before 1940, there was no consistent framework for establishing or communicating diamond quality. De Beers thought they had great diamonds, but they struggled to get paid a premium for them.
So they teamed up with the ad agency N.W. Ayer to come up with two clever campaigns. The first was their iconic “A diamond is forever” campaign that made diamonds the default for engagement rings.
But the second was all about establishing the "4 Cs" grading system: Cut, Clarity, Colour, Carat. The system had already been created by the GIA (Gemological Institute of America), but De Beers used their marketing prowess to make it the consumer standard and to shape the perception of what a “good” diamond is. They gave consumers a clear standard and language to define quality.
Mental healthcare is more complex than selling diamonds, but there would be benefits for businesses and clients to steal some of De Beer’s ideas. There are several clinically validated standards for what constitutes great mental healthcare. A business should partner with the right organisation, co-opt one of these standards, brand them and market them to consumers in a way that establishes a new, transparent standard for high-quality mental health care.
Diamonds aren’t the only thing that benefits from clarity.
Resisting the temptation of AI
The demand for access to therapy intoxicated many Mental Health businesses in the first half of the 2020s. But there’s a new cheap drug on the market, AI. Demand for conversational AI support is exploding. I do believe there is huge potential here and that mental health businesses should thoughtfully explore that potential and build meaningful solutions. But they must resist the temptation to offer unvalidated, unsafe products in return for growth.
It’s tempting for businesses to jump on the consumer demand for AI mental health support. It would give them new users and growth (two things most mental health businesses need). But if their tools are not ready (which most of them aren’t), they will end up harming clients in the long run, losing trust with both the clients themselves and clinicians.
If they do, there will inevitably be harm and scandals. This will damage trust. That damage may reach a tipping point, after which clients and clinicians will abandon mental health businesses in search of alternatives. If they do this, their position of intermediation will be at significant risk.
There is opportunity here, too. Defining quality also means defining what it is not. Brands within this space could be more vocal in defining why open AI models are unsafe and counterpositioning against them. Right now, this message is being told largely by the media and academia, but owning a posture on this and helping clients and clinicians to navigate this and gain clarity is an open position.
6. From Access to Accountability
As the requirements for trust shift from access to accountability, what can we say about how businesses are approaching trust building in 2025?
Let’s take a look and see what we can learn.
D2C (e.g. BetterHelp)
Most of the main D2C players are trying to build trust through emotional resonance, repetition, and ubiquity with claims like “world’s largest therapy service” or “#1 app”. The new cohort of D2C AI apps is the same. This cohort also attempts to convey scale as a proxy for legitimacy. The experience is optimised for ease, with fast onboarding and wellness cues that lower the barrier to entry. Some publish outcomes, but the data is often self-reported and housed in investor materials instead of client communications. Very little of their messaging is focused on quality or outcomes. As a result, they risk shouting about access to a crowd searching for quality.
B2B (e.g. Lyra Health, Spring Health, Modern Health)
Because the organisations have to sell to businesses, their messaging focuses on structure and ROI, anchoring in measurement and clinical rigour. Phrases like “matched to need” and “trusted by leading organisations” position these brands as steady and dependable, built to deliver consistently rather than capture attention. Clinical frameworks are evident, but rigour and transparency vary. Some messaging is slowly shifting from “we get your employees care quickly,” to “we get them care that works, and here’s how we know.” Lyra and Spring provide regular reporting across multiple study types - survey insights, outcomes and commissioned reports, financial ROI. But their client-facing messaging is still largely focused on access. Just look at this messaging from Spring’s client onboarding journey.

Spring Health Client Messaging
B2B2C players (e.g. Talkspace, Headspace)
Admittedly, the lines between all these businesses are blurring as they grow. But folks with consumer DNA who are now selling to employers and insurers are navigating a complicated middle ground. The familiar emotional appeal from their DTC roots still shapes the client-facing experience, but beneath the surface, they’re working to build enterprise credibility by investing in published outcomes, academic partnerships, and institutional affiliations. But these signals remain disconnected from the core user journey. Trust is being constructed in fragments, but the narrative remains unresolved.
Pockets of high-trust messaging
Some parts of the market have a naturally higher bar for earning trust. In these corners, we can find examples of how to build credibility and connection through accountability.
One such corner is in pediatric and family care. When families look for care for their kids, they often have higher expectations than they would for themselves. They want to understand what’s happening when, and who's involved. Companies like InStride, Brightline, and Little Otter show the full care journey, explain symptoms in plain terms, and give people timelines they can count on. Contact is direct. Pricing is upfront. Clinical claims are backed with detail. They understand that trust begins with making the experience understandable and shared.
Some Digital Therapeutics businesses offer other examples. HelloBetter and Big Health elevate research to a brand pillar and embed it in their company values, stating 'Evidence is a duty, not a chore' - so it takes on a moral imperative and adds more believability regarding their commitment to data and rigour. Big Health pits itself against the full spectrum of care, reflecting patients’ reality of choices, and even pushes off of 'wellness' apps to make a sharper contrast point.
Many of these Go-To-Market and care models are converging. Their messaging and how they try to establish trust are converging, too. To do so is to ignore a massive opportunity.
The Opportunity to Redefine Trust
The opportunity here isn’t just to maintain trust - it’s to redefine it. That means moving past a promise of access and toward a promise of accountability. To outcomes. To genuinely making people better. To do all of this for clients, but also to redefine what trust means between businesses and clinicians, too.
That means not f**king up.
But it means more than that too.
It means doing hard things. Like defining new standards for quality and investing in communicating that to the public. It means giving people clarity and helping them understand what good care actually looks like. It means resisting the temptations of easy but harmful growth, the likes which may be found in technologies like AI.
As the trust relationship continues to develop, it presents an opportunity for businesses to push away from the rest of the market, not just in their messaging, but in their actions.
We’re at a crossroads. One path leads to the positive effects of intermediation: stronger mental health businesses, better client outcomes and better working standards for clinicians. The other leads to obsolescence.
Let’s see which path leaders chose.
That’s all for this week. As always, reach out and let me know your own thoughts on this topic.
Keep fighting the good fight!
Steve
Founder of The Hemingway Group
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