The saga of the Google changes that are cutting access to natural health and integrative content continues. The Academy of Integrative Health and Medicine (AIHM) suddenly had all its Google advertising summarily removed. Phoenix integrative pain doctor Michael Cronin, ND first saw all of his clinic’s Google ads for two leading edge pain strategies taken down. Then his clinic’s ads related to women’s health and family medicine supporting his partner’s practice also were removed. AIHM’s are back up after much negotiation, but still amidst mystery that seems to lead directly into the belly of the big data beast. Cronin gained some clarity about actions against his advertising, without stilling concerns. This article offers guidance based on what each experienced and has learned, plus perspectives from natural products quality expert Michael Levin who has feet in both the natural products and pharma camps.
This is a fourth in a series on Google’s actions relative to information on natural products. Please see articles below.
Stem cells and platelet rich plasma injections are no-nos
The take down of Cronin’s is the most understandable – at least partially. He states that regenerative injection procedures are commonly used to treat musculoskeletal trauma, overuse injuries, and degenerative issues, including failed surgeries. Other therapies include the use of amniotic and adipose stem cells and injections of “PRP” – platelet rich plasma, the result of a process in which blood extracted from the patient is enriched through an in-office process, then injected back into the injured locations of the patient.
After the ads Cronin has run for over five years were suddenly removed, he researched Google’s advertisement policies in the area of health and Medicine. There, under “Speculative and experimental medical treatment,” he found this prohibition:
Promotion of speculative and/or experimental medical treatments is prohibited. Examples of products and services that will be prohibited (non-exhaustive): Stem cell therapy, cellular (non-stem) therapy, gene therapy and similar forms of regenerative medicine, platelet rich plasma [PRP], biohacking, do-it-yourself (DIY) genetic engineering products, and gene therapy kits.
Through a September 2019 change to its advertising policy that was implemented in October 2019, Google’s bots discovered Cronin’s clinic and took down the ads. Cronin discovered not only that all of his Google advertisements had been taken down but they found that no Google ads were appearing for PRP and stem cells for any and all providers all around the country. While his “organic” Google searches – those for which prioritization is based on factors other than Google’s AdWords – were still working, he notes concern that there may be “hidden restrictions there as well.” Cronin followed Google’s appeals process and learned that as long as the suddenly forbidden therapies are in his drop down menus, Google will prohibit ads of any kind from his clinic.
Cronin, a practitioner of nearly 40 years whose professional life has included terms as the president of the American Association of Naturopathic Physicians and a current term heading the Integrative Medicine Consortium, said his first response was anger. He now acknowledges that when he first started advertising his work with stem cells, he thought that he might be causing himself some problems putting himself on the edge. Given the fact that he uses stem cells on just 1-2 patients a month – “the cost is higher and the evidence is not as strong as that for PRP” – relatively easy for him to take down.
On the other hand, Cronin uses PRP with multiple pain patients every day. He wonders at Google targeting the treatment, noting that “PRP is an offering of many orthopedic doctors and pain management doctors are using it like crazy.” A quick search netted this notice on PRP services at Johns Hopkins Medicine. The page mentions no controversy nor questions about the effectiveness of PRP and begins its education for patients this way:
PRP treatments can enhance hair restoration and other cosmetic plastic surgery procedures. The platelets, one type of blood cells, contain growth factors that can trigger cell proliferation, speed healing and stimulate tissue regeneration in the treated area.
Notably, PRP is also featured on Hopkins’ promotion of their plastic surgery program. I looked but could not readily discover whether Hopkins is advertising its PRP via AdSense.
Cronin, who has led multiple efforts in his profession to drive more research in multimodal naturopathic methods, sent an email to Levin the day after our interview referencing an article on one of his news feeds entitled “FDA released an app for physicians to tell the agency about their successes with existing drugs used off-label for hard-to-treat infections.” Levin called attention to this in the FDA’s statement:
Health care professionals generally may choose to prescribe or use a legally marketed human drug or medical device for an unapproved or uncleared use when they judge that the unapproved use is medically appropriate for an individual patient.
Cronin found it ironic that he was getting docked by Google for doing something – providing off-label treatment – that the FDA is facilitating elsewhere.
The mysteries of the AIHM encounter
Google has a generous Google Ad Grants program through which not-for-profit charitable organizations receive up to $10,000 per month of free advertising. AIHM executive director Tabatha Parker, ND explains that while AIHM has been gratefully using it, the sudden take down was particularly odd: ““I was surprised that our ads were disapproved as we never have anything in them related to clinical services. They are all advertising educational programs. We’ve never even offered sessions on stem-cells. That’s not what we do.” She referenced a list on the Google site that clarifies its exclusions:
AIHM doesn’t provide any medical services. We don’t ‘do’ anything in that list – all of our ads were around membership, fellowship, education – joining an interprofessional community in integrative health & medicine. All 18 of our ads were flagged under the same ‘Speculative’ issue.
Parker shared a communication with AIHM’s consultant on their social media – a marketing person who focuses only on Google ads – that fully supported this. AIHM requested a review, as Cronin has done when he discovered Google’s lines he’d crossed over. Parker shared that Google’s 20-something code writers, who clearly were part of no nefarious plot, also did not have good answers as to what had happened or of how to prevent them in the future. They moved to reinstate, which proved to be challenging. As soon as the ads went up, Google’s police-bots took them down again. “Clearly there is something beyond the wall that they don’t like.” This cycle happened multiple times. As of the interview on Thursday, 5 November, the ads were up. Says Parker:
Collectively we’ve probably spent 20 hours on this. We still don’t know why they were taken down. And they could come down again at any time for reasons that Google support can’t clarify.
Perspective from Michael Levin – “collateral damage in Google’s risk management”
Entrepreneur and adviser Michael Levin of Clackamas, Oregon-based Health Business Strategies, is unusual for his experience as an executive in pharma, devices and natural products companies. In the latter over the past 25 years he has developed a specialty in product quality. When Cronin discovered his Google problem, he informed a small set of colleagues via email that included Parker, Levin, and me – due to my prior writing relative to trying to understand Google’s actions. Levin was already familiar with Legitscript, a company that that advises Google on pharma and natural products issues and to whom Google turns publicly on its site that provides advertising guidance.
Levin noted – and Cronin and Parker agreed – that Google’s 9 bullet-point list of products and practices for which advertising is forbidden is generally a good one. (One that on first read can seem worrisome – “Herbal and dietary supplements with active pharmaceutical or dangerous ingredients” – clearly is referencing natural products into which pharmaceuticals have been illegally added.) In an interview, he offered a big picture perspective:
Web analytics and search engine optimization are new. Maybe what we are running into is a collision of a technology that has moved far in front of regulation that has collateral damage through risk management brush strokes that are too broad.
Levin notes that Google is “clearly using technology to screen out ‘bad words’ content.” It is happening across the board in multiple fields including politics. He examined Google’s most recent annual report for useful signs.
They proudly declare that machine learning and artificial intelligence is ‘driving many of our latest innovations’. It appears that your ad placements are victim to artificial intelligence. Likewise for our friend, Erik Goldman, at Holistic Primary Care.
Lenin shares sections of the annual report that suggest that their core interest is in risk management. Google sees its self as “subject to increasing regulatory scrutiny as well as changes in public policies governing a wide range of topics that may negatively affect our business.” The firm “may be subject to legal liability associated with providing online services or content.” They tick off their competitors in the search engine business: Among the general purpose search engine competitors, they name: Baidu, Microsoft’s Bing, Naver, Seznam, Verizon’s Yahoo, and Yandex.
In addition, new products and services, including those that incorporate or utilize artificial intelligence and machine learning, can raise new or exacerbate existing ethical, technological, legal, and other challenges, which may negatively affect our brands and demand for our products and services and adversely affect our revenues and operating results.
One corporation’s “collateral damage” is another’s “life”
The Buffalo Springfield lines in “For What It’s Worth” that “there is something happening here/but it just ain’t exactly clear” never seemed so appropriate. Levin makes a good case that Google’s core interest is risk management. It aligns with Holistic Primary Care editor Erik Goldman’s more cynical view that Google is managing risk of “fake news” in the natural health field to curry favor with regulators, especially regulators with public health interests. What remains clear is that Google has bigger risks to fry. Google’s decisions on how to implement its regulatory strategies relative to potentially questionable integrative health content are gnats on an elephant’s back relative to the uprisings, suppression, genocides and revolutions that are also impacted by this private company’s self-regulatory choices. This is the broader context in which Google is struggling to put artificial intelligence in charge of very real worlds.
Still, since the bots don’t seem to be too good at taking a meeting, Parker’s experience has made clear to her that the whole integrative health field needs somehow to get past Google’s 1-800-number and connect with human beings that are upstairs from the young techies. In political terms in the United States, one hasn’t a right to conscientious objection until one has tried everything. Similarly, thinking the worst of Google’s intentions toward integrative – given its multiple relationships with conventional pharma – requires first getting inside and suggesting that Google create an advisory team that knows the integrative field to assist them in the area of natural and integrative health. Google needs to answer the door – and the field needs to knock.
Note: This article was updated with clarifying and new comments from Cronin December 8, 2019 at 1:50 PM ET.
Other Articles in this series: