Medical and pharmaceutical industries, which typically outpace other industries when it comes to embracing technology, have been relying on social media for clinical trial recruiting for years.
FDA Regulations on Social Media
Since the emergence of social media, the Food and Drug Administration (FDA) recognized the power, the ubiquity, and the risks of social media. As a result, the agency conducted hearings seeking input from consumers, manufacturers and medical professionals in helping to shape the future social media policy – especially when it came to clinical trial recruiting. FDA officials were particularly concerned about the limitations inherent in social media such as Twitter’s 140-character constraint – and if such confinements would shortchange consumer access to full disclosure. (In 2009 alone, the FDA warned 14 pharmaceutical manufactures that their digital advertisements failed to fully disclose the risks associated with certain drugs.).
Over the course of the next five years, the FDA issued a series of decisions indicating it was attaining a degree of comfort with regards to drug makers using social media, and in 2014, the agency issued final rulings regarding pharmaceutical companies’ use of social media.
At a high level, the FDA declared that all social media marketing must provide equal time to assess both a drug’s risks as well as its potential benefits. The agency also made clear that no misleading social posts would be allowed, and that social posts must provide consumers hyperlinks giving them access to all drug disclosures. Additionally, the FDA required all pharmaceutical social media metadata be retained for future scrutiny. At the time, one Forbes reporter said the underlying message was clear: “Firms can expect to be held accountable if these standards are not met.”
So where does that leave today’s medical and pharmaceutical organizations hoping to use social media to recruit clinical volunteers?
Patient Engagement Through Social Media
In 2015, one industry publication warned companies to be aware of and not let the relaxed vibe of social media cloud their judgement: “Social media and digital media can have a much more informal feel than traditional advertising. While most of us would ask someone else to review anything we wrote for a newspaper, few of us ask for help before we post something on Facebook or Twitter.” The point being regulators will scrutinize post just as diligently as they will a broadcast or print ad.
To make expectations even more clear, FDA.gov now lists requirements for medical researchers recruiting volunteers via social channels. Included on the list are the following:
- Social advertisements should not suggest "free medical treatments," when, in fact, participants, are simply not being charged to take participate in a subject recruitment.
- Advertisements can tell participants they will be paid, but posts should not emphasize payments using larger or bolder fonts than what is used throughout the rest of the post.
- Recruitment ads should primarily focus on only what is needed to determine “eligibility and interest” of potential participants.
Additionally, although not required, the FDA asks those recruiting for clinical trials to include some of the following information in their social posts:
- The name and address of the clinical investigator and/or research facility
- The purpose of the research
- A summary of the criteria used to determine who can participate
- An overview of potential benefits, if any (for instance, a “health examination at no cost”)
- The expected time commitment
- Link for consumers to follow to learn more information
Despite any limitations these regulatory requirements may present, it appears that the use of social media in clinical trials is here to stay. According to a 2016 study completed by pharmaceutical giant Merck & Co., only about half of the world’s pharmaceutical manufactures currently use social platforms at all – and less than 5% of those using social media to recruit trial participants. However, the study concluded, this is bound to change: “As more and more companies engage with patients on social media, it will be important for companies to utilize social media for trial recruitment.”
If you are curious about the growing role social media will play in clinical research, the George Washington University’s online MSHS in Clinical Research degree can provide you with the latest insights into the health care industry.