SOURCE: Hale AdvisorsDESCRIPTION:
By Zoe Dunn
There are a lot of good POVs on the FDA’s recent Draft Guidance around Social Media (a sampling here, here, here and here). So at Hale Advisors, we decided to focus on a couple of items that caught our attention:
Correction of Misinformation
As we wrote last fall in the “Let’s Face it: Wikipedia is a Public Health Issue; Now Let’s Fix it” article on PharmExec’s blog, healthcare companies should own the responsibility for correcting misinformation about their products and services. Now the FDA has made it official, and we commend them.
Wikipedia commands a surprisingly powerful influence; for example, medical articles on Wikipedia receive about 150 million page views per month. And while the impact on consumer information and opinion is of note, it is very concerning that nearly 50% of practicing physicians use Wikipedia as an information source for providing medical care. This means it’s more important than ever for the industry to find a way to participate and provide the best and most accurate sources of information possible.
In its most recent draft guidance, the FDA says that drug companies have a public health responsibility to correct misinformation. But it’s also a customer trust issue: Pharma’s reputation is harmed by misinformation. To maintain/regain credibility, the industry must ensure that the best and most clinically correct information is disseminated for public consumption. However, it isn’t Pharma’s job to ‘police’ consumer-generated content, especially since marketers have neither the resources nor the bandwidth. People are, after all, entitled to their opinion, even if they are wrong. Therefore, the FDA will not punish the pharma manufacturers that correct the information (so long as there’s no promotion involved) nor will they punish those who do not.
Platforms with Character Space Limitations
So, while the “Correction of Misinformation” Guidance seems on the right track, we can’t necessarily say so for the Guidance on “Social Media Platforms with Character Space Limitations.” This is a major concern, and it undermines the customers’ experiences with Pharma on social media platforms. The FDA seems to be sending a clear message that branded promotional activities on certain social media platforms are a big no-no. It’s impossible to include the brand and generic name PLUS a balance of benefits and side effects in 140-character tweets. And while branded promotion in social media should have very clear tie-in to business objectives, this guidance might take a big chunk of that social media messaging off the table…we hope this guidance isn’t a foreshadowing of what’s to come from the FDA when it gets around to addressing mobile guidelines.
As we wrote in pharmaphorum in March, with this new guidance, the FDA is essentially forcing the industry to do a “bait and switch” move with unbranded, misleading URLs that send customers on a roundabout way to branded sites. This directive further undermines Pharma’s credibility with the consumer, erodes consumer confidence, and—for those consumers looking for unbranded, condition-related websites—gives them branded drug messages that they’re not ready for.
Other things to keep in mind about the draft guidance:
- By requiring that Pharma marketers put a drug’s benefit, chemical name, most important risk information and link with product name, and the word risk all in a limited place, the FDA is basically eliminating such platforms as Twitter and Instagram from Pharma’s marketing quiver. But this is SILO thinking – as if Twitter use were the only messaging platform consumers consult when considering a course of treatment. That’s just untrue.
- Consumers are exposed to Important Safety Information in many places, such as Pharma’s branded websites, HCP offices (patient/physician discussions, pamphlets, samples, etc.), and the pharmacy (pharmacist/patient discussions, insert in the bag). Including it in tweets is overkill.
- By severely limiting branded messages on Twitter, the FDA is forcing Pharma to use unbranded URLs—in effect, using shady tactics and being evasive with consumers, which engenders mistrust.
- The FDA could be supporting Pharma in improving public health, rather than the negative “do no harm” approach. This guidance presupposes that Pharma has bad intentions in its use of character-limited social media platforms.
- There is a need to have Pharma’s voice in the social space as they are the ones who are keepers of the science behind their drugs. The FDA would be more helpful if it provided guidance on how to use social channels rather than what not to do.
- Twitter can be a valuable customer service tool; now the FDA has handcuffed the industry so Pharma can’t help customers (and fulfill its public service mission) through this channel.
In summary, we give the FDA one thumb up and one thumb down on its draft guidance. Tell us how you see the proposed rules affecting your business – leave a comment below.
KEYWORDS: Health, content marketing, digital, FDA, marketing, policy and guidelines, social media health, FDA draft guidance on social media, FDA and pharma, character space limitations, FDA rules on Twitter