All companies should be using social media as an integral part of their social media strategy right?
Not quite!
For a long time my answer would have been very different – however working closely with the healthcare industry has changed my opinion.
The healthcare industry (among others) has always faced strict guidelines on what and how they advertise ensuring the correct balance between information on both risks and benefits. The industry has been waiting for such guidelines on the use of social media marketing since 2009.
In December, the FDA released the first (of many) draft guidelines on one of the topics which are currently being discussed ‘responding to unsolicited requests for off-label information about prescription drugs and medical devices.’
Dale Cooke, vice president and group director of regulatory review at Digitas Health, a health-care marketing agency claims that this draft is a good start as it shows that the FDA ‘is starting to incorporate social media into its thinking.’
It would be impossible for the FDA to release guidelines for each of the platforms out there (e.g. Facebook, Google +, Twitter) as there are so many that will come and go.
However, it is intended to produce guidelines on as many topics as possible as it did with this draft. For example, in this draft the FDA says that if a firm encourages users to post videos or comments about their own uses of a drug on a social media site, it might result in someone talking about their off-label use of the drug. And if that leads to questions about off-label use of the drug, it could be considered illegal promotion on the part of the company.
Unfortunately, this example would suggest that they are recommending that Pharma companies don’t ask for their patients to share experiences on an online platform; however this is not the case because the sharing of experiences can be extremely beneficial for all involved. This highlights that there is still room for improvement within this draft.
So what is the solution? Or is there one?
Cooke recommends ‘companies review their plans for soliciting patient testimonials and avoid using Twitter and other microblogging sites for announcing the results of clinical trials related to unapproved uses of a drug or product. Companies should also make sure that discussions of off-label information — in social media or not — are handled by medical affairs departments and use one-on-one communication rather than a public forum to discuss off-label information with a questioner.’
Unfortunately the FDA’s latest draft and Cooke’s advise has not solved the social media problems facing the Healthcare industry, who for now it seems cannot reap the benefits the rest of us are enjoying from the thriving social media process.
Read more:
The Wall Street Journal, FDA Has (Some) Social Media Advice For Pharma, January 2012
Hi Gary,
For even more supplemental reading on the issue I’d like to link to DoseofDigital’s post at http://bit.ly/A4Zqj6
as well as Intouch Solutions at http://bit.ly/A2Xe4R . Both offer fairly optimistic takes on the new FDA Draft Guidance.
Hope your readers find those helpful. As I keep saying on this issue; “It’s Progress.”
Cheers
Jason Boies
Radian6 Community Team
@Radian6
Thank you for sharing those – I am sure our readers will enjoy having the extra information and you are right, it may only be a small change but it is a change in the right direction!