Most marketers agree that social media is the place to be for engaging with consumers, but that’s not so easy for some product categories -- and pharmaceuticals is definitely high on the list, due to well-founded concerns about regulatory scrutiny and legal liability.
However Intouch Solutions is hoping to make it easier for pharmaceutical companies to interact with consumers through social media with a new service, SocialQueue, which enables pharma companies to monitor and manage social activity with a platform that complies with all the manifold regulations imposed on the industry.
SocialQueue’s features include close monitoring of content produced by brand representatives as well as consumers; automatic updates, alerts, and analysis of activity across social channels; and activity recording, which simplifies the process of auditing and reporting social activity.
Intouch Solutions noted that 40% of consumers said they relied on information found on social media to make healthcare decisions, and Intouch CEO Faruk Capan added, “We're seeing an increasing number of clients that want to engage in open dialogue on social media platforms. The key to doing this in a regulatory-friendly way is with a tool like SocialQueue, which provides a safety net.”
Regulatory rules for pharma marketing on social media have been coming in dribs and drabs, at best. In June the Food and Drug Administration finally suggested some guidelines (draft guidelines, actually) for how pharmaceutical and medical device manufacturers can use social media to market products and correct misinformation.
The marketing guidelines acknowledge that third-party social media venues like Facebook and Twitter often have limited space to explain products and make disclaimers. However the FDA emphasized that drug and device marketers must still comply with the original rules governing promotional messages, including the requirement to give information about specific indications, and balanced disclosures about the product’s risks as well as its benefits in each individual communication -- meaning a statement about risks has to be in every Tweet, Facebook post, and so on. Whenever possible, special formatting should be used to highlight the risk information. If it’s not possible to cover all the risks, the most serious risks should be prioritized, including “all risk concepts from a boxed warning, all risks that are known to be fatal or life-threatening, and all contraindications from the approved product labeling.”
In all cases the company should also provide a link to more complete discussion of risks associated with the product; although the FDA doesn’t object to URL shortening, it recommends that the link to risk information indicate the nature of the information contained at the landing page, e.g., “www.product.com/risk.” Finally, if there isn’t enough room to make a reasonable disclosure about the drug (for example, when the risks are especially serious or complicated) on the social media venue, the company should reconsider using that venue to promote it.
In the second draft guideline, dealing with correcting misinformation on third-party sites (for example Wikipedia or discussion forums) the FDA acknowledges that given site constraints it may not be possible to make all the usual disclosures about a product while engaging with the site. In these cases, if the firm is not responsible for the original statement it is not required to make the full product disclosures in its statement, provided all the information in its own statement it provides is correct; the company should also identify itself as the source of the new information, and should not try to use the correction as an opportunity to promote the drug.