The stem cell clinic industry selling unapproved “therapies” is ubiquitous and yet somehow still growing it seems. Many of us are encountering more of them including via ads and the clinics are basically all over the place.

What should someone do if they see a stem cell clinic that is particularly concerning?

A lot of people are asking me this question lately.

There are a variety of options depending on your level of concern, but below is a guide to possible actions you can take via agencies such as the relevant state medical board, the FDA and the FTC.

To be clear, not all stem cell clinics rise to the level of being “sketchy” and some are even compliant with FDA regs even if I’m skeptical that what they are doing is effective, but there are loads of seriously bad clinics out there.

If you feel a situation is especially dangerous due to adverse outcomes or other unique concerns, drop me a note by email and I can try to help in some way.

Otherwise, what can you try to do to make a positive difference?

State Medical Boards

A good place to start is with your state medical board.

Where specifically?

This will depend on your specific state. Usually state medical boards have contact phone numbers and/or emails on their websites. A quick web search usually pulls up the medical board for your state.

Here in my state, for instance, the Medical Board of California website has helpful resources (e.g. see screenshot) and you can also file a complaint by email here. You can complain about risky stem cell clinics in Texas here and in Florida here.

Because state medical boards regulate physicians (and technically not their clinics it seems), you will need to know the name of the physician at the clinic to include that in raising your concern. Complaints to medical boards and potential action by the boards are taken very seriously by physicians, perhaps in some ways more seriously than worries of possible FDA action.

The Federation of State Medical Board (FSMB) issued a report largely on stem cell clinic issues earlier this year that suggests they are possibly going to take on the problem more directly than in past years. We’ll see how that goes.

Chiropractor regulators

As I was writing the above section on state medical boards an interesting question came to mind: who regulates chiropractors? It’s not medical boards. Normally it wouldn’t be the FDA either, although since chiropractors are now involved in injecting unapproved stem cell drugs, the FDA should get involved. The more direct regulation of chiropractors comes from state chiropractic boards (it seems all states have them). I would turn to them to file a complaint.

There’s also something called the The National Board of Chiropractic Examiners at the federal level, but they just seem to do licensing tests. I’m not sure if this other organization would do any good.

Would any of these do anything meaningful about chiropractors administering risky stem cells in an unethical manner for profit? I don’t know, but it’s a real and growing problem someone needs to address.

FDA

You can reach out to the FDA to let them know your concerns. The FDA is a very big organization so where specifically can you make a complaint or raise a concern? There are various options. You can start with an email to: [email protected]. Will the FDA do something concrete in response to your concern? It’s hard to say and if they do take action it might unfold over a long period of time.

FTC

A very large number of clinics make questionable marketing claims about their “stem cell” offerings, ranging from wild claims of cures for incurable diseases to implying their product has living stem cells when it doesn’t.

I asked the FTC what people should do if they are concerned about a stem cell clinic. You go to the FTC website and in the upper right corner you click on “Fire a consumer complaint”, which I highlighted with the red arrow in the image above. Then click through the various choices. I would recommend clicking “other” as the category and then “health and fitness”.

The FTC took action on two stem cell clinics and their owner this year, but if there might be 800 clinics out there now and many of them making false claims, the FTC needs to do a lot more.

Hosts of Ads

Depending on where you saw an ad for the clinic, you could contact the entity who is running the ad like Google, your local paper, etc. to complain.

What to say

What should you say in your complaint about a stem cell clinic?

It will depend on who you are talking to you. I would emphasize concrete reasons for concern such as the use of an unapproved stem cell drug product by the clinic, a physician practicing outside their area of expertise so putting their patients at risk, false marketing, and potential or documented (if they’ve already happened) patient harms. For some clinics that aren’t led by physicians, I would also emphasize the risks of non-physicians such as chiropractors or Ph.D.s doing procedures for which they aren’t trained or licensed. I think patients (or people communicating on their behalf) making complaints about clinics and their personnel will have the greatest impact.

In the long run

We can make a difference by pushing back on the worst clinics. Of course, not every action by those of us in the stem cell arena who are concerned about predatory clinics will hit a bullseye to make real change, but sometimes it has happened in the past and will happen again in the future too.

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