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Original Research |
Katrina A. Bramstedt, PhD, Bioethics Department, General Clinical Research Center, Research Subject Advocate Program, Cleveland Clinic Lerner College of Medicine, 9500 Euclid Ave, Mailcode JJ-60, Cleveland, OH 44195
Reprint Requests: Katrina A. Bramstedt, PhD, Bioethics Department, General Clinical Research Center, Research Subject Advocate Program, Cleveland Clinic Lerner College of Medicine, 9500 Euclid Ave, Mailcode JJ-60, Cleveland, OH 44195, Tel: 216-444-8720, Fax: 216-444-9275, Email: txbioethics{at}yahoo.com
Received: August 28, 2006.
Revised: December 11, 2006.
Accepted: January 11, 2007.
| Abstract |
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Methods: In this study, 119 advertisements recruiting health volunteers and listed on the CenterWatch Clinical Trials Listing Service website were reviewed for content as well as text style and visual effects.
Results: The majority of advertisements satisfied FDA guidance. However, 21 (18%) were ethically troubling with regard to font size, font style, and/or verbiage. In many advertisements, it was unclear if "medication" meant "investigational drug," "over-the-counter medication" or US FDA approved "prescription medication." Nearly 30% of the 119 advertisements used the terms "free," "no charge" or "no cost" as lures.
Conclusion: Ethically problematic recruiting advertisements can be coercive and misleading. Descriptive guidance provided in this paper can help clinical researchers create ethically appropriate recruiting advertisements.
Key Words: Advertising Internet Healthy volunteers Recruiting Research subjects
Once given visual form, any text is implicitly coded by that form in ways that signal, however subtly, its nature and purpose and how its creators wish it to be approached and valued.1
Recruiting volunteers is an unavoidable, often time-consuming and difficult task in clinical research. Internet marketing of research studies occurs in various forms including websites dedicated to specific studies, clinical trial databases which store an aggregate of basic information about actively recruiting studies, and direct email solicitation to Listserves or target populations. Investigators and sponsors use Internet marketing because it potentially reduces their postage and printing costs, content delivery is instantaneous, and the amount of content is potentially limitless. While not all potential research subjects have personal computers with Internet access, such is available for free at virtually all public libraries. Even some hospitals have medical information libraries with computers dedicated specifically for patient use.2
Because clinical trial databases aim to recruit research subjects, they are a marketing tool, and therefore the content and visual appearance of the data entered are relevant to the concepts of coercion and deception. Specifically, words can be displayed in a variety of forms due to variations in the elements of the letter design (typography). Type style and use of bold font or slanting (italics) are forms of visual communication, and in this way, the typeface garners ones attention, speaks to the reader and even stimulates semantic meanings.3 As an example, car manufacturers carefully select their advertising fonts due to the meanings and associations they can project (e.g., elegance, power, confidence).3,4 Similarly, it has been argued that the "old fashioned" font style used by Wendys (www.wendys.com), a US restaurant chain, may convey the feeling that their hamburgers are old fashioned and even wholesome.5
The US Food and Drug Administration (FDA) requires that institutional review boards (IRB) review and approve the materials and methods used to recruit human subjects,6 additionally, the FDA provides guidance regarding Internet advertising.7 Specifically, the FDA does not require IRBs to review Internet listings of clinical trials as long as the listings provide only "basic trial information" (e.g., study title, study summary, study location, contact information). Internet databases that are designed with formal system limits (e.g., font size, font style, entry of only basic study information) satisfy this guidance, and thus, do not require IRB approval for each study listing. Two examples of such databases are the National Cancer Institute Physician Data Query Clinical Trials Database (http://www.cancer.gov/search/clinicaltrials) and the AIDS Clinical Trials Information Service (http://www.aidsinfo.nih.gov/ClinicalTrials/Default.aspx?MenuItem=ClinicalTrials). Both databases cross-link to another database (www.clinicaltrials.gov), with all three using a standardized data set consisting of 20 items that describe the study in detail (table 1
).8
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If the content of study advertisements is not automatically limited by software design (or manual approaches that ensure adherence to the "basic trial information" guidance), IRB review and approval should be obtained. This is because ethically inappropriate recruitment materials (e.g., those that use eye-catching visual cues or verbiage to promote study benefits) create the potential for prospective volunteers to underestimate or dismiss their risk of harm. This study explores the recruitment of healthy volunteers using a popular Internet database that does not use a standardized data set for study listings. The results of this study facilitated creation of Internet recruiting guidance that is applicable to all potential research subjects.
| Methods |
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| Results |
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Advertisement Design and Verbiage
No database advertisements contained special effects such as animation, flashing text or institutional/sponsor logos. Ten of 119 (8%) used words or sentences containing all capital letters in locations other than the study title. Three advertisements (3%) used exclamation points, three (3%) used bold font for words or phrases not in the study title or subheadings, and one (0.8%) used large font in an area other than the study title. The majority of advertisements satisfied FDA guidance. However, 21(18%) were ethically troubling with regard to font size, font style and/or verbiage (table 2
). Fourteen of these 21 advertisements (not shown in table 2
) were vague when describing the drug used in the research, using terms such as "medicine" or "medication" instead of descriptive terms such as "investigational drug," "over-the-counter medication" or "FDA-approved prescription medication."
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Study Type and Procedures
Twelve of 119 (10%) advertisements were specifically recruiting for vaccine studies. Of these studies, 4 were recruiting for HIV vaccine studies, 3 for genital herpes, 2 for human papillomavirus (both enrolling pediatric research participants), one for cytomegalovirus, one for meningitis and one for herpes simplex virus (pediatric participants). Fifteen of 119 (13%) advertisements were specifically recruiting for studies involving an "investigational drug." Four of 119 (3%) advertisements indicated the studies involved phase I research (drug, vaccine). The remaining advertisements either used vague terminology such as "infusion," "medication" or "medicine" to describe the agent under study (n=14). It is impossible to know how many of the 119 advertisements were recruiting for drug/device/vaccine and non-drug/device/vaccine studies because some ads were vague or completely nondescript in describing the nature of the study.
In addition to exposure to investigational drugs and vaccines, study procedures included but were not limited to blood withdrawal (26 advertisements), magnetic resonance imaging ("scan") excluding dual energy X-ray absorptiometry or other imaging excluding X-ray (14 advertisements), electrocardiogram (3 advertisements), glucose tolerance test (2 advertisements), bone marrow donation (2 advertisements), spinal tap (1 advertisement), saliva/mouthwash sampling (1 advertisement), breast duct lavage (1 advertisement at each of 12 study sites), bile sampling using a nasoduodenial tube (1 advertisement) and cytapheresis (1 advertisement). Thirteen of 119 (11%) recruitment advertisements did not contain any description of the study activities.
Compensation
Specific compensation (e.g., dollar amount) for study participation was mentioned in 56 (47%) of 119 advertisements. Unspecified compensation (e.g., "You will be paid for your time") was mentioned in 33 advertisements (28%). The concept of compensation was not mentioned in 28 (24%) recruiting advertisements. Two advertisements (2%) indicated that no compensation was offered for participation. With regard to specific compensation, the largest amount offered was "up to $4,280" for up to 8 weeks inpatient participation involving studying "medication effects." Other types of compensation offered included free group therapy, $25 shopping mall gift certificates, $10 bookstore gift certificates, smoking cessation classes, smoking cessation class referral, cholesterol testing, and meals, movies, reading materials and videogames during on-site research participation. One study site offered use of a 27 inch TV/DVD/VCR combination with satellite receiver during on-site participation.
Review of the compensation offered by the nine advertisements that were recruiting pediatric participants found that the highest specified compensation was $40 (involved researchers observing the interactions of parents and their children). Three advertisements seeking to enroll pediatric participants indicated compensation would be provided but did not specify the amount. Two advertisements made no mention of compensation for pediatric participation. Thirty-four of 119 (29%) advertisements used the words "free" [meals], "no charge" or "no cost" [exam] to describe research subject benefits. No recruitment advertisement for any study mentioned compensation for injuries occurring during study participation, and none mentioned if subjects were required to have their own health insurance as a condition of enrollment.
| Discussion |
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The results from the current study indicate that the OIG recommendation does not go far enough, as the typology of recruiting advertisements can also be ethically problematic. Database recruiting advertisements can emphasize compensation and other benefits not only via the verbiage chosen, but also by text appearance (e.g., bold face type, block capitalization, italics), and this creates the potential for volunteers to focus on the benefits and underestimate or dismiss the risk of harm that can directly result from participation.20,21 In addition to the clinical impact, personal financial impact can be significant for the uninsured or underinsured as most studies do not provide free medical care to treat adverse events resulting from study participation.16,22
Data collected during this study also indicate that while recruitment advertisements seek "normal, healthy volunteers," these same studies sometimes require the healthy volunteers to have a history of emotional and physical trauma,23 be overweight,24 be current tobacco smokers,25 or current marijuana or heroin users.26,27 Are these people actually healthy? Might they be at greater risk with certain types of procedures or exposures to investigational drugs? Do addictions to tobacco, drugs or even food render people unhealthy from psychological, as well as physical perspectives? These are critical questions that research teams, sponsors, IRBs and the FDA must ponder when reflecting on study design and research subject safety.
Adverse events are a risk in all research studies, even those involving healthy subjects. A vivid example is that of the superagonist anti-CD28 monoclonal antibody (TGN1412) trial that triggered nearly fatal cytokine storm reactions in six healthy participants.28 The data collected in the current research study indicate that healthy volunteers are being recruited for a variety of study procedures. Drug and vaccine studies pose the risk of allergic reaction, among other events (e.g., vomiting, fever, abnormal blood count, muscle wasting, seizure). In the case of human immunodeficiency virus (HIV) vaccine studies, HIV-negative subjects sometimes mistakenly believe that the vaccine provides protection against HIV infection, and then they engage in risky sexual behavior.29 There is also a theoretical risk that the vaccine could enhance the ability of the virus to cause infection due to the creation of non-neutralizing antibodies.29
Invasive techniques for specimen retrieval (e.g., spinal tap, bone marrow donation, cytapheresis) carry risks, as do experimental procedures such as special diets and exercise regimens. Imaging procedures using contrast agents have the potential for life-threatening reactions. Some risks, such as birth defects and fertility problems, might not evolve into reality until after study participation is complete. Although rare, death can be a complication for healthy subjects participating in clinical research studies.3032 While investigators must be diligent about using the informed consent process to educate potential participants about study risks,33,34 a thorough informed consent process does not justify use of deceptive or coercive recruitment materials.
Not surprisingly, the data from this research study revealed no recruiting advertisements that mentioned the potential for adverse events or the plan for responding to (and paying for) research-related injuries. In the US, research institutions and sponsors are not required to compensate or provide free treatment to participants when they incur research-related harm. Few study sponsors and institutions automatically ensure free medical care to research subjects injured as a result of participating in their studies.3539 Notably, the National Vaccine Injury Compensation Program excludes injuries resulting from the use of unlicensed [research] vaccines.40
| Conclusion |
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Recruitment advertisements for healthy volunteers, as well as patients, should not overemphasize compensation or use coercive or deceptive lures. All recruitment materials (e.g., Internet listings and websites, flyers for posting on bulletin boards) should be an honest snapshot of the research project and should not contain problematic text effects or verbiage (table 3
). Advertising study remuneration is not unethical as ong as it is not highlighted or emphasized causing it to stand l out from other concepts in the advertisement. Also, the amount should not be coercive, but should reflect the burdens of study involvement.
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A limitation of the current study is that it did not include an analysis of sponsor-created recruiting websites (e.g., www.stepstudies.com). The content of such websites is vastly greater than that of a database listing, usually consisting of multiple web-pages that use text, audio and video to describe the study, its risks and benefits and testimonials from prior research subjects. Future research could analyze the content of a sampling of such websites. Additionally, future research could include focus group methodology to explore various advertising layouts (visual presentation including font size, style, verbiage) for the emotional responses triggered by the readers (including any ethical discomfort) and assessing the relationship of the emotional response to the likelihood of pursuing study enrollment.41 Ethical attention to the design of recruitment advertisements is critical to avoiding deception and coercion of potential research subjects.
| Acknowledgment |
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