9 March 2014
PO Box 3132 Victoria Gardens
Richmond VIC 3121
RE: Proposed “Guidelines for advertising regulated health services”
In 2012 you released a consultation paper on your then proposed social media policy. Feedback from the Australian healthcare social media community was swift and negative. I am relieved that you subsequently undertook a consultation and significantly revised your proposed social media policy. However, I am dismayed that your lack of understanding of social media communication has resurfaced in your proposed “Guidelines for advertising regulated health services” that is scheduled to take effect on March 17, 2014.
According to Section 6.2.3 of the proposed Guidelines, from March 17 over 600,000 registered health practitioners will need to ask any individual who writes online about their clinical care, or any website that hosts the online comments, to remove the comments.
Your Guidelines state: “A practitioner must take reasonable steps to have any testimonials associated with their health service or business removed when they become aware of them, even if they appear on a website that is not directly associated and/or under the direct control or administration of that health practitioner and/or their business or service. This includes unsolicited testimonials.”
Following an outcry on social media the Medical Board of Australia released a media statement on 7 March stating that “the Board recognises that practitioners are unable to control what is written about them in a public forum”. After initially defending the AHPRA Guidelines and stating that the Board’s hands were tied, Medical Board Chair Dr Joanna Flynn stated: “there is a clear difference between advertising – which requires an intent to promote the health services – and unsolicited online comment over which practitioners do not usually have control”. The Medical Board’s about turn on this matter is prudent. Indeed, if Section 6.2.3 of your proposed Guidelines applied to medical practitioners then members of the Medical Board would soon find themselves needing to contact Australian and overseas websites asking that online testimonials of their own clinical practice be removed.
Your proposed social media and advertising Guidelines of 2012 and 2014 demonstrate AHPRA’s complete lack of social media expertise. Health practitioners wouldn’t implement clinical practice guidelines that were developed by individuals who have no experience or expertise in the field. So why would you propose to implement Web 2.0 communications guidelines that have been developed by individuals who clearly have no experience or expertise in this field?
AHPRA, please place your proposed Advertising Guidelines under immediate review and ensure that healthcare social media experts are consulted in the development of any future AHPRA guidelines pertaining to social media. If you don't know how to reach social media experts let me make it simple for you. Just send me the login details for your inactive Twitter account and tell me any time you’re in policy development mode. I'll get the word out on your behalf, and then all you need to do is what healthcare social media experts do every day: listen, engage and learn.
Dr Jill Tomlinson
MBBS(Hons), PG Dip Surg Anat, FRACS(Plast), GAICD
Plastic, Reconstructive and Hand Surgeon
This letter has been written to AHPRA upon request following a phone conversation with AHPRA – reference VIC2107284. It follows this letter to the Medical Board, the Medical Board’s initial response, and the Medical Board’s recent backdown or backflip. At the time of publication of this letter the Medical Board of Australia's media statement dated 7 March 2014 is not listed on the relevant page on the Medical Board's website. Interested readers can download it here.
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