If the blog is intended to specifically recruit subjects to a study, the blog content needs to be IRB approved. However, many blogs contain educational information regarding the clinical research process and/or a disease state. An article may reference at the end, “check out our website for a list of current research opportunities.” These blog articles do not recruit for a specific study, per se, but still provide a medium for study recruitment. The referral page mentioned at the end of the article may need IRB approval, but reference OHRP’s guidance for more information.
There is a gray area when a public relations piece is published on a specific study. For example, let’s say a study has launched and is going really well. You are featured in the newspaper or on a website discussing the study and its purpose. Can that be considered a recruitment piece? Well, if you are still open to accrual, it could definitely generate some interest and draw leads. However, if you are not opening an invitation to recruit, it technically isn’t recruitment material. A good rule of thumb is, if you do provide information more than just directory listing (study title, purpose of the study, protocol summary, basic eligibility criteria, study site locations, and contact information), seek IRB approval. Again, talk to your IRB for institution-specific policies, as these are generalities based on the minimum requirements of the federal regulations.