07 Feb Using social media in pharmaceutical advertising
Social media is all the rage. And healthcare marketers are always looking for the latest, greatest communication tools. But the use of social media in pharmaceutical advertising is controversial and risky. There are, however, several ways a drug company, medical device manufacturer, hospital, or other healthcare organization can use social media effectively and safely.
The web is crawling with people eager to share their opinions—good and bad—about drugs’ efficacy and safety. Misinformation is often rampant. Complete prescribing information is often absent. And the rules governing the use of social media in pharma advertising have yet to be fully defined.
Never make the mistake of thinking that the lack of regulations means that anything goes. On the contrary, the FDA is closely watching pharma companies’ social media efforts for unethical promotions. Likewise, never make the mistake of thinking that by sponsoring a third-party site, even with an unrestricted grant, you are absolved of responsibility for its content. Your association with a website—however remote your connection may be and however strong you think the firewall may be—potentially makes you liable for its content, including conversations in discussion groups.
So how can a pharmaceutical company use social media effectively while minimizing the risk of regulatory infractions? First, maintain as much control as possible. Second, let four words guide you: “on label” and “fair balance.”
Regarding the issue of control, the safest route is to interact only on websites, branded or non-branded, that your company wholly owns and operates. There are exceptions. Have you visited the “GI Circle” on the American College of Gastroenterology site? The ACG site for physician specialists has numerous corporate sponsors. It also features a discussion board. The topics for this open forum, however, are generally not patient management issues. Instead, they focus on topics such as healthcare reform. The common wisdom is to avoid talking about politics or religion. But in social media, even talking politics is preferred to talking therapeutics.
So beyond taking the risk of sponsoring a site where physicians may talk with each other (and the world at large) if not about the efficacy and safety of your product then about its price…and short of hunkering down and not using social media at all until regulatory questions get resolved…what’s a pharma or biotech company to do?
One idea is to use social media to make e-advisory boards more interactive and robust. Ad boards can have a dedicated website, which includes a forum for discussion groups. Ad Boards can meet via Webinars, key content may be repurposed by posting it on YouTube and disseminating it via physician peer-to-peer e-newsletters and blogs. And of course, new postings on the website, blog, and YouTube get promoted (with links) in Twitter tweets and other networking sites.
To maintain a presence in the blogosphere, some pharma companies opt to have their Medical Director author posts on therapeutic issues as long as they go through the regulatory committee approval process. The key is to keep all messages on label and always include the fair balance and full prescribing information. A pharma company’s Medical Director may also oversee surveys and other activities on the physician social networking site Sermo.
But it’s not just a pharma company’s Ad Board key opinion leaders and its Medical Director who must be cautious. Virtually all employees must be regulatory-sensitive when communicating via social media. Of course, this applies to the sales force and the claims they express on sales calls and in correspondence with customers. But it also applies to office staff members’ emails, Tweets, Facebook posts, and more. Issue a clear policy to your employees at all levels on why and how to use social media safely and effectively.
A pharmaceutical company, biotechnology company, medical device company, diagnostics manufacturer, hospital—virtually any organization in healthcare—should definitely consider including social media in its promotional mix. However, for best results, partner with an experienced healthcare marketing agency. A good agency can help you minimize risks and stay on strategy, on message, and on schedule with your social media efforts.