The deadline has passed (February 28), but a new submission was posted – this time from Yahoo! to the FDA's Social Media Docket that was set up in the wake of the November Part 15 meeting related to the use of the Internet and social media in medical product promotion. In fact, however, it is about social media use at all, not just for promotion, but for education – the fact that the title never reflected that might reveal a biased mindset on the part of the FDA, but that is neither here nor there for now.
The Yahoo! submission quoted back to FDA some of the usual statistics and some I had not heard before including:
- 91 million Americans use the Internet to access health information at over 1700 sites (had not heard that one);
- 78% of Americans suffering from a medical condition who are online visit a health-related website to learn about their condition and 56% of caregivers do the same;
- And quoting Manhattan Research, the number of Americans researching prescription drugs online has doubled since 2005 to 102 million people.
They then provided some insights into their own internal research on Internet use as it relates to prescription drugs.
"Over half of online Americans are on prescription medication with a fifth having done some research regarding some prescription drug medication. Patients are learning about new prescription drugs through a plethora of sources – both online and offline. However, online searches were the second most popular way these consumers obtained prescription drug information at 28%, compared with 44% who learned about the drug from their doctor and 24% who learned about a drug from a pharmacist. Search is a clearly common and mainstream way for consumers to obtain drug information and the online space is becoming a key driver in how consumers are learning and researching about medication."
You may be wondering why there are still documents appearing in the docket despite the fact that the docket was closed on February 28. So was I, so I asked Dr. Jean Ah-Kang, Special Assistant to DDMAC's Tom Abrams. You may recall that it was my March 2009 podcast with her that began the public dialog with FDA on the issue of social media. Here is what she said today about the status of submissions and the late entry by Yahoo!
"The Yahoo! submission was submitted prior to the deadline and just posted yesterday due to some technical issues… The docket is technically closed, and people will not be able to submit electronic comments on regulations.gov since that is no longer an option (the "Submit" function is not available through our docket). However if someone is still very interested in submitting comments, please ask them to contact me directly – thanks!
She also indicated that the Division of Dockets Management reviews each submission prior to posting for all dockets, which means that there is a lag time between the time of submission and posting. Electronic submissions will go through more quickly than hard copy.
Dr. Kang's email address is Jean-Ah.Kang@fda.hhs.gov
And one hopes that in the future, FDA ditches Regulations.gov. It is cumbersome. It is not user-friendly. And, it is not timely.