Recruitment Advertising

Academic medical centers, by their nature, function in an open environment where physicians strive to make their research widely known to the community. How then are we to know what is an advertisement (or other recruiting mechanism) that requires IRB scrutiny before it can be released and what is ‘business as usual?’

Advertisements for recruiting are usually study-specific and not generic statements about research conducted in a particular setting (e.g., Surgery Department) or for a given group of diseases (e.g., cardiovascular disease). Advertisements for recruiting are designed to be conveyed to potential participants, either directly or through an intermediary such as a referring physician. The fact that something is accessible on a website does not in and of itself make it an advertisement intended to be conveyed to a potential participant.

Web Postings providing details of eligibility criteria and study procedures in lay language, those describing potential benefits of the research (as opposed to the specific aims or scientific objectives of the research), and descriptions of compensation all would be viewed by the IRB as elements of an advertisement. Advertisements for recruiting are designed (at least in part)
to solicit a response from potential participants, and hence provide contact information to reach individuals responsible for entry into that study. Statements such as “To see if you are eligible to participate, call…” or “For more information about participating in this study, contact…” would be viewed by the IRB as elements of an advertisement. A generic statement such as “Speak to your doctor if you are interested in participating in a cancer clinical trial” or “To hear more about the research efforts of the Department of Radiation Oncology…” would not, in and of itself, constitute an advertisement for recruiting.

Please note that there is no reason why researchers should not employ web-based or other recruiting mechanisms. However, researchers are reminded that any such advertisements require IRBMED review and approval, and when modified the IRBMED must approve the modification. If an advertisement or posting is modified, the research would have to provide the IRBMED with the text of the modified advertisement before it was posted on the website. If the text on the website is identical to text being used in flyers or newspaper advertisements, then the IRBMED only needs to receive one ad with appropriate indications that this ad will be displayed as a flyer in the department’s waiting rooms, as an ad in the local news, and on the departmental website.

With these elements in mind, we believe that the IRB can do its assigned job of reviewing patient recruitment advertisements without putting an undue burden on investigators or departments. Please let us know if you have any questions or comments. Thanks for your ongoing commitment to the protection of human research participants.

The IRBMED requires that advertisements include the IRBMED number of the study. On a case-by-case basis, the IRBMED may waive this requirement, particularly for national advertisements of multi-site studies.

For additional information, refer to FDA guidelines about recruiting study subjects.

Researchers are NOT required to use these templates. They are offered as an example of the type of flyer typically approved. You may change the fonts, colors, add logos, artwork, etc. Do not make monetary compensation a larger font than the expected risks.

The flyer must be saved and uploaded into eResearch as a .DOC or .DOCX to enable the watermarking function.

Approved September 13, 2005 by University of Michigan IRB Council

Definition: Non-study-specific recruitment communications are those materials that do not specifically relate to an IRB-approved study/protocol/program. These materials are typically general in nature. They serve to facilitate subject recruitment by raising awareness, delivering information about being a research subject, and providing links to information about specific research participation opportunities.

Elements include:

1. Non-study-specific portal to match subjects to specific studies and registries
2. Generic information for prospective subjects
3. Research announcements that promote research in general to community and are intended to inspire interest of prospective subjects

Examples include:

1. Web sites
2. On-hold scripts
3. Advertisements (print, radio, TV)
4. Brochures/pamphlets
5. Press releases

Policy

1. IRB approval is not needed for non-study-specific recruitment
2. Non-study-specific recruitment communications should follow guidelines

Guidelines

Authority

As complaints or concerns regarding content come to the attention of institutional authorities (ultimately OVPR), these authorities will present the guidelines to recruitment content “owners” for correction.

Contact Michigan Medicine Public Relations for assistance and advice in developing these types of communications.

Created 4/17/2012