New Social Media Guidelines: What FDA Says, and What It Means

Earlier this year, FDA promised three sets of guidelines to clarify using social media for pharma marketing. Last week it delivered two of them

The first, Internet/Social Media Platforms with Character Space Limitation-Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices, (whose title alone won’t even fit in a tweet) is what we’ve all been waiting for. How would FDA guide using channels with severe space restrictions, like Twitter or paid search? We were hoping for some out-of-the-character-limit thinking, but while pharma’s been given the go-ahead to participate, the requirements for branded communications are so restrictive that it’s a moot point.

The second, Internet/Social Media Platforms: Correcting Independent Third-Party Misinformation about Prescription Drugs and Medical Devices, is really more of a clarification. It gives parameters for proactively addressing inaccuracies on third parties and social media. This likely won’t affect much, but it does paint a clearer picture for pharma marketers.

Assuming you’re too busy to read 30 pages of dry, regulatory documentation, we’ve summarized what FDA said, what FDA means, and what it means for you.

TIGHT RESTRICTIONS IN TIGHT SPACES

What FDA said: Even under the harshest character limitations, FDA wants to see a drug’s risks in equal balance with its benefits, including at least one link (and in some cases, multiple links) to dedicated safety pages.

What FDA means: FDA has ensured that if space is limited, anything more than a reminder ad (ads mentioning the brand but without any claims) will be entirely off-putting to consumers. Because after presenting all the risk that FDA wants to see, there’s no room for anything else, making the platforms laughably unusable for branded communications.

For example, in search ads, FDA suggests using sitelinks (subpages appearing below the main link) to drive to “the most serious risks,” while describing the indication with the main link. But in FDA’s example for the fictitious drug Headhurtz, the ad appears so dominated by safety information that it becomes terrifying. Their example would look like this:

In branded tweets, FDA suggests that you include the indication and the most serious risk information directly in the tweet, along with a link to a page “devoted exclusively to risk information.” After that, using FDA’s example for the fictitious drug NoFocus, you have 23 characters left to say everything else. Their example would look like this:

Good luck engaging your consumers with that tweet!

What it means for you: Headhurtz and NoFocus better describe what happens when a consumer sees a branded communication of FDA’s design. But don’t fret. Given the burden of presenting safety information, reminder ads and unbranded communications will emerge as more important options for reaching consumers.

If consumers are searching for disease-state information, unbranded communications will be key. They drive great engagement and are more relevant to the consumer’s search anyway.

For consumers ready to learn about a brand, we suggest reminder ads. By the time consumers are at that stage, they probably know what a drug is indicated for. Reminder ads see some of the highest click-through rates of any type of search ad and aren’t bursting at the seams with safety warnings. But when it comes to Twitter, the reality is more sobering: a reminder ad-based Twitter profile is probably about as boring as it gets.

THE RIGHT WAY TO RIGHT A WRONG

What FDA said: FDA gives you the go-ahead to correct misinformation about your brand online-on social networks, blogs, etc. This applies to content from an independent author (not content you directly influence or control). You can do this by contacting the site owner or posting corrective information directly in the forum. How much you proactively correct is up to you, though you can’t pick and choose based on whether it casts your brand in a negative or positive light.

There was never a prohibition on this kind of corrective action, but the FDA has clarified a few things, and has given its blessing to engage with consumers for the sake of medical information accuracy. To put it succinctly:

1. Within a defined space, if you correct one piece of misinformation, you should correct them all. So, if there are multiple errors in a single user-generated comment, you should address all or none.

2. Avoid using slogans, taglines, or patient profiles from your marketing campaign.

3. As part of the correction, you should include a link to your product’s labeling.

4. If done according to the guidelines, there are no filing requirements for these voluntary corrections.

What it means for you: Chances are this won’t change much of what you’re doing. But this does represent an opportunity to approach a customer interaction with clear guidance from the FDA-a rarity in social media.

You probably don’t have the resources to correct every bit of inaccurate information online. But correcting the most egregious pieces of misinformation, positive or negative, shows consideration and builds rapport with your consumers. A game changer? No, but good clarity to have nonetheless.

Simon Beins, Heartbeat Ideas & Heartbeat West.