Avoiding Cherry Picking

I spoke at CBI's Social Media summit on Friday. It was a good session with lively discussion.

Among the questions that came up was addressing the FDA guidance on correcting misinformation. Attendees were interested in how to avoid the accusation of cherry picking what is correcting.

I emphasized in my response the need to have policies, procedures and documentation to handle this effectively. Specifically, your procedures for correcting misinformation should require (among other things) that the people who are responsible for correcting misinformation must clearly indicate prior to the review being conducted, exactly what they will be reviewing. They might specify a blog post, or a series of comments, or all blog posts between certain dates, etc.

Then, the people should identify ALL misinformation identified within that pre-specified area.

Separately, there needs to be a standard evaluated for determining what level and types of misinformation will be corrected. For example, only correcting misinformation about currently approved indications or correcting all misinformation regarding the product safety and risks but nothing regarding its efficacy.

Finally, the procedure for correcting the misinformation has to be spelled out.

Falling all of these procedures, and applying those procedures and standards to everything that is found without regard for whether the information being corrected is positive or negative about the product should protect companies from the accusation of cherry picking.

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