12 Feb 4 actions healthcare companies can take to avoid regulatory violations on social media sites
Companies marketing healthcare products and services are eager to use social media to reach their target audiences. However, healthcare marketers are wary of violating FDA and/or FTC regulations. As a result, many pharmaceutical companies, medical device manufacturers, hospitals, and healthcare marketing agencies are “policing” their own social media initiatives by taking four important actions.
Action 1: Always keep content on-label
The potential for communication of off-label claims is one of the hazards of using social media. The best protection is to develop a clear message strategy that shows the approved talking points regarding a medical product’s indications, effectiveness, and safety.
Action 2: Always include fair balance
Most pharmaceuticals and medical devices include mandated fair balance statements that must always accompany (and balance) claims of product benefits.
Action 3: Always provide complete information on product safety and use
If the use of a product, its indication, efficacy benefits, or safety profile are even mentioned—let alone described in any detail—the brand’s complete safety information must included. In the case of pharmaceutical and biotechnology products, this takes the form of prescribing information for patients and clinicians.
Action 4: Never enable an open forum where consumers and/or professionals can exchange information that is potentially off-label, inaccurate, or incomplete
This is healthcare marketers’ worst fear—facilitating an uncontrolled discussion of off-label information or simply misinformation. Providing a real-time, open forum is strictly a no-no.
Not surprisingly, among the companies using social media effectively, even within regulatory constrictions, is one that is located close to Silicon Valley and recognized as an industry pioneer: Genentech.
For example, Genentech has created an online community for people with cystic fibrosis and their caregivers. The site is designed to promote the company’s Pulmozyme® brand. Genentech also has created the Herceptin® online community for breast cancer survivors. Neither provides a forum for uncontrolled discussions or for posting of comments.
Bayer takes a similar approach with their Betaseron® online community for people with multiple sclerosis. In fact, there are numerous social media sites focused on MS, a chronic disease whose sufferers and caregivers crave information, empowerment, and support.