I'm taking issue with the increasing prevalent view as represented in this Bloomberg article that has an unstated assumption that it's reasonable to expect or even demand that actors such as Google take measures to make these moral judgments.

If Google wants to and chooses to, great. But if they don't, I'd much rather see an article warning the public about the dangers of trusting Google ads rather than bemoaning that its easy for bad actors to buy Google ads.

And Google isn't 'helping' bad actors unless they charge them less than others or otherwise create an unfair advantage. Otherwise they're a neutral actor that is a reflection of a failed policy and/or law enforcement problem.

Bloomberg is in the Advertising business, they'll never take the stance that you shouldn't trust advertising. Their customers won't accept that.

So we get this. Blame google.

I'm sympathetic towards the argument that Google should do more, but besides banning these advertisements overall, how should Google verify a legitimate clinic vs an illegitimate clinic? Would these proposed solutions actually get in the way of scammers, or would they just add to the cost of doing business with no real gain for consumers?

The states (most, at least, and I think all) already take care of the verifying: you need a license to operate a treatment center. Google should require that they submit information about their state licensure to run a treatment facility. Patient brokers and sham operators presumably aren't licensed treatment providers and wouldn't be able to meet that standard, and if they're found to be falsifying their documentation, rather than just being booted from adwords they should be turned over to their respective states for criminal prosecution.

I work in the addiction industry, on the marketing side. I can tell you that the licensure requirements are generally a joke. Only Florida, California, and maybe a couple other states are tougher to open a treatment center instead of, say, getting licensed as a hair stylist.

Until the past year or so, all levels of government were unable to track down the shady operators. IMO, it's not Google's job to do what law enforcement was unwilling to do. (Now, Google could be extra ethical on this, but why would they be? Generally, we expect corporations to follow law enforcements lead, rather than hold them to a higher standard.)

I think the topology of information flow should determine who is responsible for doing what.

If Google is practically speaking the gatekeeper for these kind of shady dealers (because it sees both the consumer demand and the bad actors), then the most efficient system is one where Google is given both the responsibility and the tools to do the regulation.

In fact, Google might be in a better position to regulate this than the states are. What should the states do -- individually browse for ads on Google and then call up those places? This still places Google front and center.

This is the same reason central planning is a horribly inefficient system -- yes, in principle you can have the entire economy send their data to the central government, then the central gov't comes up with a plan and redistributes it to every factory -- but in practice a lot goes wrong in putting so many links.

I disagree, the onus falls on the state to actually make the licensing process strict.

How can Google be expected to do this at scale? To act as an extra layer of regulation that even local government cannot or will not provide?

> To act as an extra layer of regulation that even local government cannot or will not provide

Whoever possesses the data and information is the only actor who can meaningfully perform regulation. You can't effectively regulate blindly.

Right now Google has the most data, more than the various state and local governments.

So there's really two possibilities:

1. Google is 'responsible' for the regulation, under the delegated authority and monitoring of governmental bodies

2. Local governments retain the responsibility to regulate these entities, but they need the power to compel the necessary data from Google so they can do the job. That requires a lot of trust in various levels: that Google provides the correct data, that there is a way for local government to act on it, and for there be the right social 'API' in place where Google only shows ads from licensed entities.

At the end of the day, these are practically speaking the same thing, except we use different language to describe it. The 2nd possibility has more hops in it, so it's less efficient, but maybe it's safer.

It's kind of like how we do money transmission and terrorism finance regulation now -- the government is nominally responsible for making sure bad actors can't send money, but the only way to do that is for banks, PayPal, et al to send data to the government.

I thought we were opposed to Google using heavy-handed tactics to police the Internet. What if Google's enforcement ended up kicking a marginalized person off of their ads platform, or required advertisers to put their Real Names on their ads?

> I thought we were opposed to Google using heavy-handed tactics to police the Internet

When it comes to unpopular or corporation-unfriendly speech, yes. When it comes to outright scams, no.

I wouldn't call not actively helping bad actors promote their scams "heavy handed", anyway. Are rehab scam operators "marginalized persons" now?

Think of it as less of a binary. It's not "scam operator" or "legitimate operator". Much more nuanced -- the stories are about the clear scam operators, but that may or may not be the long tail. And that long tail may or may not be what we want to optimize for.

One of the major characteristics of a "scam operator" is this situation: Andy runs a treatment center that only takes Cigna. He gets a call from Bob, who has BlueCross. Bob can either do private pay at Andy's Center, for $20k. Or Andy can refer Bob to Mike's Center for BlueCross Patients, where Bob can get treated for $5k out of pocket.*

If Andy and Mike have a business relationship where they refer patients to each other, and either end up benefitting, they are breaking the law.

* Option 2: Andy tells Bob "sorry, we can't treat you. Try calling someone else."

That's not a solution - most states' licensing agencies are underfunded and ill equipped to fully vet these organizations. Many of these shady organizations have licenses.

That's just an argument for not cutting funding of government regulators. It's also a solid point against the little-to-no regulation folks who think the free market will solve every problem.

Problem is that addiction treatment is still in the dark ages. It's poorly regulated and often not evidence based.

http://healthland.time.com/2012/06/26/addiction-treatment-in...

>finds that most addiction care is administered by “addiction counselors” for whom there are no national standards of practice. It finds also that 14 states don’t require any education or licensing at all for addiction counselors. The risks to those seeking treatment can be dire: California is one of the states that allows uncredentialed providers, for example. In a recent case in that state, a sexual predator was found to be offering “intimacy therapy” to addicted teenage girls; treatment consisted of sex with him. Without oversight, there’s no way to stop people from preying on vulnerable people under the guise of addiction care.

>Only six states require addiction counselors to have a minimum of a bachelor’s degree; just one requires a master’s degree, according to the CASA report. The main qualification for treating addiction in this country is having suffered from the disorder oneself — a standard of care that would be considered absurd if any other medical condition were involved.

Even regardless of whether state licensing is sufficient (plenty of comments indicating it is not), how do you verify an ad based on these documents?

Is there a government database you can query? Does it contain all the valid contact details, e.g. website, phone numbers, so that they can actually verify whether an ad comes from the actual entity.

Ignoring the latter part will just land us in the same place as before.

The article is about Florida, where these legal protections haven't existed until recently.

Hooray for the free flow of commerce across state lines, so Florida clinics can import 75% of their "customers" form out-of-state.

Datum: medium and large treatment providers are willing to pay around a $5,000 CPA in sales and marketing costs. A huge amount of this, on average, goes to Google.

Just by removing AdWords from the equation, Google could reduce per-admit costs by thousands of dollars. (Of course, those costs would likely just go to third party lead resellers, who are in the grey area of patient brokering IMO)

When an ad is pennies, or even a buck per click, I can see your argument.

At over $100 per click Google can investigate every single one.