Social Etiquette

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The trouble with social media is that drug companies are control freaks—as they should be, the regulatory climate being what it is. But the promise of these emerging media is too great for pharmas to opt out of entirely.  

There have been a few experiments by pharmas in the space. Novartis dabbled in user-generated content with its November FluFlix contest on YouTube, asking users to post two-minute videos on how the flu makes them feel and offering three $500 prizes. In October, Arimidex-maker AstraZeneca launched CelebrationChain.com, an interactive effort for breast cancer awareness that allows patients to create virtual paper doll likenesses of fellow survivors and email them to recipients. Pfizer signed up with physician online community Sermo. 

But it was GlaxoSmithKline that took social media the farthest, creating a patient community and even a blog for its OTC weight loss treatment Alli. Online support features prominently in advertising, with images of patients tapping away at their computers. 

Social media offers pharmas the prospect of dialoging with patients, much as they do healthcare professionals, says Jack Barrette, founder and CEO of WEGO Health. 

“This is perhaps the first time word-of-mouth marketing and opinion marketing have been available on a programmatic basis,” says Barrette. “You have a chance to engage them just as you would a group of physicians.”

But blogs, wikis and online communities being regulatory terra incognita, companies are understandably wary about getting on the wrong side of FDA or OIG in a space where the rules are hazy. In a recent White Paper, a trio of firms suggested that healthcare companies can stay on the right side of the law by following the existing guidelines on broadcast and print advertising.
Adverse events reporting tops pharma concerns about social media. But these concerns are often overblown. For instance, since many commenters are anonymous, posts seldom meet FDA's criteria for credible adverse events reports that must be passed along to the agency. 

Another worry is off-label promotion. Should a commenter on a company-owned site discuss an off-label usage, is the company in violation? Maybe. But companies can limit liability by reducing the control they have over a forum—for example, by sponsoring sites run by third parties through unrestricted educational grants. 

“If you don't control the content, you're not engaging in promotion,” says Fard Johnmar, whose company, Envision Solutions, co-authored the paper with TNS Media Intelligence/Cymfony and law firm Seyfarth Shaw, LLP. “You're just providing a forum.”

Marketers might fulfill fair balance by using the same “one click” rule they apply for web and email marketing, including a prominent link to PI info in postings. 

“The industry was having the same questions about paid search five years ago,” says Paul Ivans, president of consultancy Evolution Road. “They're all trying to figure out ways of separating church and state.” 
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