So, the big news on DEC 3rd was the announcement by the FDA and WebMD about their “new partnership to inform and educate tens of millions of Americans”.
According to the press release…
The U.S. Food and Drug Administration and WebMD today announced a collaboration that expands consumers’ access to the agency’s timely and reliable important health information. This joint effort reflects the FDA’s emphasis on using innovative, technology-based strategies to carry out its foremost mission, which is to promote and to protect the public health…
The partnership includes:
- A new online consumer health information resource on WebMD.com (www.webmd.com/fda): Consumers can access information on the safety of FDA-regulated products, including food, medicine and cosmetics, as well as learn how to report problems involving the safety of these products directly to the FDA. In addition, WebMD will bring the FDA public health alerts to all WebMD registered users and site visitors that request them. The cross-linked joint resource will also feature FDA’s Consumer Updates—timely and easy-to-read articles that are also posted on the FDA’s main consumer Web page (www.fda.gov/consumer).
- The FDA contributions to WebMD The Magazine: FDA Consumer Updates will also be featured at least three times a year in WebMD’s bimonthly magazine, which reaches nearly nine million consumers. The magazine is distributed to physician office waiting
rooms across the country.
As soon as the news broke on Wednesday (DEC 3rd) morning, it was quickly picked up on the Twitterverse and plenty of discussions erupted around the topic of this new relationship.
On the one hand, people were encouraged by the fact that the FDA was finally reaching out and “fishing where the fish are” — i.e. not expecting consumers to come to the FDA website to find important FDA-regulated product info, but to proactively publish info where consumers already typically turn to (i.e. WebMD). After all, and through their own admission, “The FDA Web site currently receives approximately 6 million visitors per month, most of which are representatives of regulated industry“, meaning that it’s not the average consumer, but mainly organizations that are regulated by the FDA (e.g. pharma, device manufacturers, etc.) that visit their website.
On the other hand, there’s also a concern about the “fairness” of a relationship between the FDA and a for-profit, pharma-sponsored organization. I mean, I have absolutely nothing against WebMD and I’m all for the for increasing public awareness by using consumer channels to engage them, but doesn’t an exclusive partnership with a for-profit company seem a bit like a bit of an endorsement?
Here’s a portion of the Memorandium of Understanding (MOU) between the FDA and WebMD that disclaims their endorsement — for some strange (suspicious?) reason, the PDF has disappeared from the FDA website at the time of posting this blog:
Focusing on point #2, there is an obvious and intentional purpose NOT to imply an FDA endorsement of the “product, service or Web site”. However, since no other health portals have the same arrangement with the FDA, wouldn’t the public perceive it that way? And wouldn’t such a relationship/partnership imbue an added level of trust and inherent promotion associated with WebMD, leading to increased traffic and, ultimately, financial gain?
Would this be similar to having a single sponsor for a CME event, instead of a multi-sponsored event? Isn’t the big reason for having multiple sponsors to show impartiality towards a specific organization?
Is it just me? Am I reading too much into this?
Having said all that, an interesting element in this scenario is that, according to their general Co-branding Agreement...
- Co-branding arrangements are not exclusive. Entering into a partnership agreement does not restrict FDA from participating in similar initiatives with other public or private agencies, organizations or individuals…
- Both parties agree that information FDA provides to co-branding organizations shall be public domain material. FDA shall have full rights to reuse the content for all FDA purposes, and the right to share with other collaborators or requestors.
In other words, the content that the FDA publishes on WebMD is not exclusive to WebMD — they can choose to publish it with another partner and it also belongs to the public domain, so anyone can repurpose the content. As someone on twitter said, “…so WebMD is just acting as the aperture through which FDA content can be repackaged and distributed“?
There’s also a bunch of other criteria that need to be adhered to as a partner, including the following for content display:
- FDA Consumer Health Information should be easily distinguishable from non-FDA content. Placement of FDA Consumer Health Information on the Web or in printed publications should be clearly identified as such. Examples of clearly identifying FDA Consumer Health Information would be placing this information in a box and/or using a distinct color to distinguish it from non-FDA content, and/or otherwise clearly distinguishing the non-FDA content via an adequate disclaimer statement.
- Printed and online pages containing FDA Consumer Health Information must be free of advertisements to avoid implying FDA’s endorsement or support for a particular product, service or Web site.
So, I’m not really sure where I finally stand on this…
Don’t get me wrong… I really like the idea that the FDA is reaching out to engage consumers in the “consumer playground” (as opposed to the old “build it and they will come” approach). But if reach is the key objective, why not partner with the top 10 health portals to give an even greater reach — just think about the Revolution Health and Everday Health merger for numbers!
I also saw another suggestion on Twitter that it “…would maybe have been better done if they’d just done open source code for updates or offered RSS feed link to all? (already there)“. Indeed, why not just create a news/media feed or even a YouTube channel that can be distributed to ALL health portals, blogs, etc. At least, in that format, not only can specialized groups select relevant information, but viral distribution will also be inherent to the system, PLUS the FDA can then collect the usage data themselves (i.e. not reliant on the individual organizations to provide them the usage statistics/analytics, etc.).
It’ll be interesting to see how this evolves going forward. The way the MOU and Co-Branding Agreement is written, it does appear that the FDA has plans to grown beyond a single partnership and I sincerely hope they do. The more they can openly engage with consumers through channels where consumers are already consuming health-related content, the closer we will get to an informed and educated patient population.
But as for execution, I personally feel that for an organization that preaches impartiality — particularly when it comes to organizations that have a financial interest (and traffic = $$$ for a health portal) — a relationship with a for-profit company that provides a potential advantage to that company over other organizations in the same industry could be perceived as somewhat biased and unfair.
What do you think?