As reported by the New York Times yesterday, the White House has tapped over fifty influencers, spanning communities on Twitch, YouTube, and TikTok, to promote the COVID-19 vaccine and help counter misinformation widely spreading from those promoting anti-vaccination messaging on similar platforms.  

In connection with the engagement, the influencers have shared Q&A sessions and Instagram live chats with Dr. Anthony Fauci, content captured while the creators received their vaccines, and more.

The state of Colorado and other state and local governments are following a similar approach; Colorado’s efforts involve paying creators up to $1,000 to promote the vaccine.

Notably (for us advertising lawyers), posts from creators associated with the Colorado campaign have included the disclosure “paid partnership with Colorado Dept. of Public Health and Environment” on their posts. It is not immediately clear whether or not the influencers who have partnered with the White House have been instructed to include any sort of similar disclosure, but many share the common hashtag #MadetoSave.

As a reminder, the FTC's endorsement guides require clear and conspicuous disclosure of material connections (i.e., connections that are not reasonably expected by the audience that might materially affect the weight or credibility of the endorsement).  That could be something as simple as #ad or it could be a contextual disclosure that explains the relationship.  Given the focus that the federal government has had on influencer disclosures over the last few years, it will be interesting to see whether the White House will require and enforce FTC-type disclosures here.