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Does the IRB need to review “dear doctor” letters or review press releases?

IRB letters Press releases review
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Does the IRB need to review “dear doctor” letters or review press releases?

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“Dear Doctor” or doctor-to-doctor letters (even when soliciting for study subjects) are not considered advertising that has to be approved by the IRB, because it is not intended to be directly seen or heard by prospective subjects. News stories and publicity intended for other audiences are not considered advertising.

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