This week the New England Journal of Medicine included a “Perspective” piece on social media and healthcare. The piece, by Drs. Greene and Kesselheim from Harvard Medical School and Brigham and Women’s Hospital, provides the author’s opinions on the use of social media in healthcare and raises three main concerns:
1. A lack of research around the impact of information shared on the Web
2. Issues around credibility and disclosure by sources
3. A need for physicians and consumers to hold FDA and pharmaceutical manufacturers responsible for the information provided via social media
Our perspective, announced when testifying at the FDA hearing last year, is a the concept of the “3 C’s Rule” of accountability for brands and content online.
Similar to the concern the authors provide in their article, our perspective is that brands should be held accountable for content if they created it (such as by including the fair balance and “Med Watch” language the FDA currently mandates in branded DTC communications) or appropriate balance in unbranded materials. Our rule also suggests being held accountable for content if they collaborated with or compensated the creator in some way (such as by briefing online influencers/bloggers or worked in tandem with a third party spokesperson to develop content that is shared online).
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