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Could the FDA’s “Bad Ad” program be coming to a patient recruitment campaign near you?

Recently the U.S. Food and Drug Administration (FDA) announced the “Bad Ad Program,” an effort to have doctors and healthcare professionals around the country report what they believe to be misleading drug ads.

Evidently, the initiative is to help the FDA’s understaffed and overwhelmed Division of Drug Marketing, Advertising and Communications (DDMAC) with more surveillance of the large volume of direct-to-consumer (DTC) promotional materials that makes its way to consumers and medical personnel every day. The measure has been largely panned in the drug advertising community as too broad, lacking in education, and questions its ability to overcome biased reporting from doctors who are already anti-DTC.

While “bad ads” do seem to be the stated battle, it appears the real concern is the way drugs are marketed that the FDA can’t see (i.e. detailing by reps to doctors behind closed doors, comments made at medical conferences, etc.) where false claims, overstated results, off-label promotion, and understated risks can be made.

Within the patient recruitment industry, there are Institutional Review Boards (IRBs), per FDA regulations, to review and approve promotional recruitment materials. However, with dozens of IRBs reviewing patient-facing recruitment materials, experience suggests that while some IRBs won’t approve certain language in recruitment materials, others will approve it with no changes. Those inconsistencies invite complaints and governmental review. Being a part of this industry for more than 14 years, I’ve seen recruitment materials overly promote the monetary benefits of study participation (i.e. visuals of dollar signs) and make promissory statements about the investigational treatment.

No doubt the vast majority of pharmaceutical DTC marketing is done within FDA requirements. Like most things in life, though, a couple of bad apples ruin it for everyone else trying to gain some false competitive edge. The same could certainly occur in the patient recruitment industry, where competition for medical research study patients can be fierce. All it takes is one ill-timed, unethical, unapproved (and arguably uneducated) recruitment ad to generate complaints that invite government scrutiny. Without a consistently high level of self-policing among patient recruitment agencies and sites, the industry may find itself also under the interrogation spotlight.


Posted by qd_admin on June 23rd, 2010 :: Filed under Advertising,Clinical Trials,FDA,IRB
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One Response to “Could the FDA’s “Bad Ad” program be coming to a patient recruitment campaign near you?”

  1. Ben Waugh
    June 23rd, 2010

    I just stopped by your blog and thought I would say hello. I like your site design. Looking forward to reading more down the road.

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