Here's something I never gave much thought to,
but should have: the Food and Drug Administration is looking at the role of social media in advertising over-the-counter pharmaceuticals, and is considering standards for a code of conduct for social
media marketers. In response, the Word of Mouth Marketing Association has submitted its own suggestions for voluntary standards, which touches on a handful of interesting issues.
Of course
social media plays a role in spreading awareness and knowledge about OTC drugs, which makes it a particularly attractive - but also tricky - medium for OTC advertisers, who hope to both trigger and
benefit from word-of-mouth promotion. There's also the fact that the Internet in general is a top destination for consumers with health care questions (allowing them to conduct preliminary research
before visiting doctors, hopefully). This obviously raises some issues, which WOMMA identified in it recommendations, which took the form of a list of "principles" and "standards." Some of these are
straightforward -- disclosing that particular communications are commercial promotion, transparency regarding the advertiser's role in creating social media promotions. But there are some interesting
issues raised here as well.
One of the first principles asserted by WOMMA: Governmental regulation concerning participation in social media by pharmaceutical companies "must only relate to
those communications that constitute commercial promotional activities sponsored by the companies," and "must be narrowly and appropriately tailored to ensure that those communications are (i)
truthful; (ii) balanced and not deceptive; and (iii) transparent." The related standard: "Companies are responsible only for those activities that (a) constitute promotional communications directed to
consumers and (b) are intentionally sponsored by the company." And another standard elaborates: "Companies are responsible for monitoring only those platforms or communications that are under their
'sphere of influence.' In other words, companies are responsible for monitoring the discussion only when they have been actively engaged in the promotional messaging within that community."
Thus, WOMMA urges the FDA to distinguish between an array of possible communications by pharmaceutical companies not directly related to commercial promotional activities, and active sales-focused
promotions. The former could include any number of "off-product" communications, issue in the course of a dialogue with consumers: for example, a list of tips for dealing with hay-fever, contact
information for support groups, or general pointers for healthy living. In other words, the focus of any FDA standards should be the substance of claims about the pharmaceutical company's products,
leaving out all the other more marginal communications that naturally occur in a social media environment. And in keeping with this focus, only the social media channels where the company is actively
engaged in commercial promotion need to be monitored.
Another WOMMA principle: "Any such governmental regulation must account for the nature and navigational realities of various social media
platforms, such as the ability to use links and space constraints in certain environments or platforms." This is sensible, but as with most "principles" it is a bit vague - who will decide what
constitutes a prohibitive constraint in an interactive environment? For example, could regulators demand links to dedicated microsites with more information about the drug and/or the social media
marketing effort on its behalf? Satisfying regulatory demands could become an endless project.