The presentations given at the FDA’s Part 15 Meeting on the Internet and
Social Media to Market Medical Products today have, generally speaking, been
focused more on adding more question logs to the fire, than offering up
solutions. There were, of course,
One of them was the
Google presentation – the last presentation of the day.
Their presentation was divided into three components – (i) a review of how
people access health care information on the Internet; (ii) the role of
sponsored links; and (iii) Google’s new proposal for sponsored links.
As evidence of the role of the Internet, Google pointed out that during just
the last 3 months of 2007 there were 4.6 billion searches using healthcare
terms made by 111 million people and that healthcare searches are growing
exponentially. That’s a LOT of
search. They also provided examples of
how access to information on the Internet can be a public health plus.
Google then made the case that since the FDA issued the April 2 Notice of
Violation letters that cited 14 companies for paid search ads covering 45
brands, there has been a sea change in the relevance of ads and their
transparency, which in my mind, reinforces the unintended negative public
health impact of the FDA’s lack of understanding of the Internet and patient
use of the Internet and of the disastrous 14 letters.
Finally, Google presentation turned to propose a new version of paid search
ads that would include links to both benefits and risk information within context of the ad, so that there is balance. They also had a version that could even be employed where a medical product has a black box warning. Here is the complete Google presentation. Download Google FDA Public Hearing FINAL
Afterwards, I spoke with Amy Cowan, one of the two Google presenters, about the goals of Google with the new paid search concept and whether anyone was yet using it.