In preparation for FDA’s public hearing on the Promotion of Food and Drug Administration-Regulated Medical Products Using the Internet and Social Media Tools, the agency is asking for comments on 19 specific questions (see “Let’s Respond to FDA’s Questions Regarding Its Regulation of Social Media“). These questions are included in my ongong online survey/questionnaire, which you can access here.
I am following the results of this survey closely and will provide updates. Here, I focus on this question:
Should the parameters differentiate with regard to the prominence of the third-party site (i.e., readership), its intended audience (e.g., general public, health care professionals, patients), its intended purpose (e.g., personal diary, encyclopedia-type reference), and/or the author of the information on the site?
The survey asks respondents to choose only one of the following responses (and add additional comments):
- Yes
- No
- No Opinion
- NA (no parameters are required)
The image below shows how respondents answered this question (ALL respondents vs. PHARMA respondents). The image will be updated frequently. See the date stamp on the image for when it was last updated. To see the most up-to-date results, please take the survey yourself and you will be able to see a summary at the end.
Many comments were submitted in response to this question. Some of these comments include:
- With the caveat that if the general public can access a site, even if it is intended for physicians, it should adhere to regulations for general public regulations.
- Only in that the “best efforts” criterion should only reasonably apply to sites that are on the first page of a Google search, or similar criteria ie. general public likely to find that information easily.
- It’s the responsibility of the content provider to make their audience aware of who they are representing. It is the responsibility of the viewer to ask in a social environment.
- It’s finding the balance between few/broad categories to avoid too much red tape and complication and one rule for all, which would detrimentally limit significant groups and not be helpful to public health.
Prominence and author shouldn’t matter, but the intended audience and purpose are relevant. - Yes, but as I have explained before pharma companies should not assume a role of watchdog.
- Health care professionals should have the correct information as determined by consensus and should be reminded to not misrepresent the information. They have more influence if it is known that they are professionals so they can cause greater damage from misinformation. Some people calling themselves health professionals are misrepresenting their real qualifications. Again, as an example, the scienceblogs will review the qualifications of an individual calling themselves a “health expert” while also commenting on the distortions of the information.
- Essential to distinguish between the general public and health care professionals!
- Companies likely to automatically ‘correct’ entries in more critical/visible places without regulation
- Third-party sites with higher readership, geared to general public, and/or encyclopedic in nature should carry greater weight in companies acting on correcting information.
- if information is wrong it should be corrected in all circumstances that the company is aware of
SPECIAL REPORT: FDA Regulation of Social Media
Find links to more preliminary results here.
