1. fiercepharma.com
Social Media for
PharMa Brand
 The emergence of social media With that safety net in place,
has posed some difficult problems brand managers can tap into the
for marketers, in some ways more experiences of colleagues who
complex than the emergence of have already taken the plunge.
ManagerS
Internet marketing channels in the After all, while the industry
1990s. may not have a best-practices
Drugmakers, for their part, manual to work from yet, early
must address even more difficult adopters in the pharma world
challenges than other industries. have begun to figure out which
Pharma managers face painful social techniques (such as edu-
consequences if their social cational forums, support groups
media promotions don’t meet and branded social media appli-
FDA requirements—and ignoring cations) can produce results.
adverse reaction reports on forums In the following pages, we’ve
like Facebook or Twitter could lead set out a guide to help prepare
to big problems as well. you for the next wave in pharma
Fortunately, the next several social media use—including
months should do much to clear a look at the important legal,
up confusion and help pharmas regulatory and strategic problems
move ahead with their social you’ll encounter. Since issues are
media plans. still in flux, we haven’t got hard-
By the end of this year, and-fast answers to offer, but we
drugmakers should be in a better hope to give you plenty of food
position to move ahead with social for thought.
media, as the FDA is due to issue Thank you in advance for
guidelines for the industry during reading this eBook. We hope it
2010. While the issues will remain helps you move forward in your
complex, such guidance should social media efforts! l
reduce the risk of mounting social
media campaigns. – Editors of FiercePharma
 Thank you To our sPonsor:
3
Meeting
5
Pharma Social
7
Sermo: Engaging
8
What Works:
9
The Future of
12
FDA Social
14
Adverse Reaction
Consumers Media Marketing Physicians Pharma’s Social Pharma Advertising: Media Proposals Reporting
Where they Live Blunders On-Demand Through Media Success DTC Goes Social Put Pharmas Challenging in
Social Media Stories on Notice Social Media
1 | June 2010 *Sponsored Content* June 2010 | 2

2. fiercepharma.com
Meeting of consumers is the foundational
information—they want to under-
the site’s tools. But 56 percent of
caregivers also visit such sites.
consumers stand their condition, learn about Pharma marketers should also con-
Where the symptoms and treatment
options and understand key terms,”
sider how consumers at different
stages of treatment and awareness
they live the Epsilon report found. Address- differ. For example, sophisticated
By Anne Zieger ing those content interests should patients may go directly to branded
be front and center for pharma drug sites, while newly diagnosed
marketers, researchers concluded. patients or caregivers may visit
 Pharma brand managers spend Then there’s the question of social sites or channels to commu-
a lot of time wondering how to who’s actually using social media nicate and share experiences.
reach consumers through social channels and visiting health sites. Perhaps most importantly, it’s
media. This is a risky proposition, According to comScore, 78 percent important to consider what behavior
given that the FDA is still weighing of people with an identified con- consumers engage in when they
what kind of social media market- dition visit health sites and use
continued on page 5
ing it will permit. As a result, some
pharma marketers have stayed
away from social media entirely, Measuring social Media roi
and others have cut off many com- expertise, the social web becomes WebMD, YahooHealth and Google- very effective. Forty percent of
munity-building features, including a rich source of consumer insight.” Health to be credible, according respondents that use web tools It can be slippery to measure ROI when you’re working in a new medi-
consumer comment functions. To date, critics argue, drugmakers to research by marketing services engage with social media tools on um. (Remember when it seemed almost impossible to measure returns
But pharma marketers don’t need have been far more prone to trans- firm Epsilon. What’s more, visitors health sites, the firm’s researchers for Internet campaigns?) But according to researcher Kevin Kruse (@
to sit on their hands when it comes fer their existing sales pitch to, say, spend an average of 91 percent found; in fact, almost 20 percent kevinkruse), there’s a well-defined set of steps that provides reasonable
to social media, or mount crippled Facebook or YouTube rather than more time on health content sites of respondents do so every week. ROI numbers for your social media campaign. These include:
campaigns. One way to keep mak- than they do on branded pharma Getting involved in these discus- • Bear in mind that while social media use may be free, creating cam-
ing progress, researchers say, is sites, according to a recent study sions is more effective than offering paigns isn’t. To estimate social media expenses, pharmas should
to spend time digging into where one way to keep making by digital marketing research firm solely branded drug content. look at factors such as staff time to be invested, agency fees, video
consumers are already getting their progress, researchers say, comScore. The most popular social Another key issue is understand- production and editing for YouTube campaigns, and the budget for
drug-related information online, is to spend time digging media sites used for finding health ing what consumers are looking making the video’s sponsored content.
both inside and outside of social into where consumers are information are Facebook and Wiki- for when they stumble across • Create a list of click-throughs that foster the goals of your marketing
media channels. Studies increas- already getting their drug- pedia, comScore researchers found. pharmaceutical advertising on the effort. For example, pharma marketers might track click-throughs
ingly suggest that if pharmas meet related information online, While websites are still pivotal web. Epsilon found that about 50 from social media content to their branded sites, disease-related
consumers where they live, social both inside and outside of channels, social media channels percent of consumers are looking sites they’ve sponsored, free trials, doctor discussion guides or
media-wise, their campaigns will social media channels. are becoming an important part of for disease-related information, and ordering brochures.
be far more effective. the mix, with 53 percent of Inter- about 30 percent are looking to • Establish which benefits you’d like to realize as a result of your cam-
“Pharma marketers shouldn’t net users reporting that they’ve check out what symptoms mean. paign. For drugmakers, Kruse suggests new patient prescription
be seduced by the bright, shiny find out how to find and connect used social media tools to discuss Meanwhile, just over 10 percent of starts and increased refills of existing scrips.
object of ‘running a social media with their audience. But if they find health topics. Thirty-one percent of consumers reported that they were • Leverage your social media presence by driving patients into
campaign’ when there’s so much out which sources consumers trust, those respondents are looking for scouting for drug information. Still, customer relationship management programs, and measure the
that they can do with social media and what types of drug informa- prescribed or available medication, 46.7 percent of comScore respon- results. For example, Kruse notes, if patients in CRM programs stay
behind the scenes,” argues Aaron tion they share, this gives pharma comScore found. dents reported that social media on a drug four months longer than those who aren’t in the program,
Gerrick, senior director of the marketers a significant leg up. Not surprisingly, Epsilon’s sites help them make better medi- that could be a $4,000 gain in revenue. In that case, pharmas could
Strategic & Analytic Consulting One data point worth considering research found that pharma cam- cal decisions, a stat that pharma assign a $4,000 value to patients who sign up after clicking on a
Group with marketing services firm is that consumers find high-profile paigns that reach out through these brand marketers can leverage. social media link.
Epsilon. “With the right tools and medical Web properties like sites’ social media tools can be “It’s clear that the main interest
3 | June 2010 June 2010 | 4

3. fiercepharma.com
continued from page 4
Yaz brand gets trashed the site. Those links are chosen to
bY Youtube videos
hold health-related conversa-
tions on social media sites. Pharma Social In theory, the brand managers
be relevant to the video users are
watching at that moment.
According to comScore, Media Marketing behind Bayer contraceptive YAZ
51 percent of respondents
said that information found Blunders were working from the right
playbook. With pharma market- Bayer lost control of
on social media sites had By Anne Zieger ers being encouraged to push its message, which
prompted them to speak their content onto social media is just about any
with their doctor about a par- sites, a YouTube channel could marketer’s nightmare.
ticular drug, and 62 percent  While pharma social media be a great idea.
planned to speak with their marketing is just beginning to Unfortunately, being one of the
doctor about a disease or hit its stride, the issues it raises first pharmas to create a YouTube In this case, the videos were
condition. have been percolating beneath channel didn’t work out the way largely placed by law firms suing
the surface for quite some time. that the company had hoped. Bayer, alongside of parodies of
Below, take a look at some Instead, Bayer lost control of its YAZ television commercials, Mack
examples of how unskilled use of message, which is just about any notes. Bayer turned off comments
social media tools can come back marketer’s nightmare. when it realized its image was
to bite brand managers. As Pharma Marketing Blog editor being compromised, but it still can’t
John Mack notes, the YAZ Birth prevent viewers from seeing these
J&J stunned bY Motrin Control Channel looks fine when inappropriate videos.
MoMs backlash viewed in its original form. But if Mack concludes, “My advice
Back in September 2009, Johnson users click on “view comments, to pharma marketers: Unless you
& Johnson’s McNeil Consumer related videos and more,” the intend to promote a real discus-
Healthcare brand began running trouble begins. They’re presented sion or upload a series of videos
television ads promoting OTC pain with the “generic” YouTube format, that will enhance the value of your
reliever Motrin. The ad suggested Twitter and used it to post com- tainly did not mean to offend which includes a sliding right-hand YouTube channel, stay away from
that mothers who “wear” babies ments critical of the ad. moms through our advertising,” panel of video links presented by YouTube!” l
Ultimately, even with in slings develop backaches and, From that point, J&J’s problem said Kathy Widmer, vice president
extensive consumer data in moreover, that mothers wear baby escalated into a crisis. Influential of marketing. “As a mom of three
hand, social media mar- slings to be fashionable and trendy. “mommy bloggers” posted items girls, I understand many of the
keting is still in transition, The response was immediate critical of the ad, other moms comments made and agree that
and drugmakers will need and angry. Not long after the ads posted videos critical of the spot we know what’s best for our kids
to experiment and learn, aired, offended mothers began on YouTube, and more than 1,300 and for ourselves.”
observers argue. The key While the statement was a good
is to simply jump in and get idea, most critics suggested that
engaged in the social media J&J did too little, too late. For one
if Johnson & Johnson had tested the social media
conversation, suggests thing, in simply apologizing and
waters and taken the pulse of real moms, it might
pharmaceutical industry moving on, the pharma blew an
never have had this problem in the first place.
blogger Steve Woodruff. important opportunity to engage in
“Measure what and when a conversation with its customers,
you can,” Woodruff says.” according to Advertising Age’s Tom
But don’t sit at the starting venting their feelings on Twitter. members of Facebook joined a Martin. Perhaps more importantly,
line when being involved in The topic became so popular that it group boycotting Motrin. if J&J had tested the social media
social networking can bring acquired its own hashtag, #Motrin- Eventually, a senior member of waters and taken the pulse of real
about so much potential Moms. Meanwhile, an aggrieved McNeil’s executive team posted moms, it might never have had this
good over time.” l critic seized the @motrin identity on an apology for the ad. “We cer- problem in the first place.
5 | June 2010 June 2010 | 6

4. fiercepharma.com
Sermo: engaging Physicians sPonsored content
by McNeil. However, it doesn’t enhance, not substitute for, real
on-demand Through Social Media can survey physicians, conduct What Works: pitch any form of medications. conversation-building.
By greg Shenk online focus groups, spark Pharma’s Social
discussions, and monitor • Johnson & Johnson Acuvue’s • AstraZeneca maintains a
organic physician dialog across Media Success Acuminder application on YouTube channel offering
the serMo coMMunitY: collaborating online, Sermo can the entire community. Stories Facebook offers the ability to updates on charitable activities
As the largest online community for provide fast, candid exchanges not remind consumers of any “little such as its support for Boston’s
By Anne Zieger
physicians, Sermo has become a possible through other channels. awareness & ProMotion details” that their life involves— Hope Lodge Center. It also
valuable resource for MDs to share Engagements that used to take Sermo does not offer traditional including, of course, reminders of presents a large number of
advice and educate each other. To months can now happen in as little advertising. Instead, it allows for  Given the regulatory issues when to change contact lenses, videos featuring AZ’s CEO David
date, more than 115,000 physicians as a few days. educational exchanges with practic- pharma companies face when buy new ones or schedule an eye Brennan. As with many other
have joined Sermo to discuss a Sermo’s business model is ing MDs about topics of interest experimenting with social media, exam. With 567 fans, it’s only a pharmaceutical companies, AZ
wide range of issues ranging from often described as a “two- such as clinical trial data, new stud- it’s hardly surprising that many minor success from a Facebook has turned off the comment
clinical cases to advice about drugs sided” marketplace. On one ies, products, or events. brand managers decide to take a standpoint—some retailers have function that accompanies the
and practice management. Sermo side, physicians benefit by In order to achieve the best pass. But that doesn’t mean phar- hundreds of thousands—and videos. Much of the material
is only for physicians and every teaching and learning from each possible outcome, Sermo ma has stayed away from it entirely. seems to have gone non- seems to involve official
member must be verified and cre- other in a private, peer-to-peer works with every client to The following case studies were functional in the roughly 15 statements more typically aimed
dentialed before they can join. setting. On the other side, Life pinpoint key messages and selected by Jay Krall of Cision, months since it was created. Still, at members of the media or at
Unlike a standard discussion Sciences Companies benefit by create a productive dialog. a public relations shop based in for a while it did a good job of Wall Street.
board, Sermo conversations engaging physicians in the Sermo This can be done in the form Chicago. Some are fairly dated, tying together real conversations
happen in the form of a post and community for market research, of a Sermo Survey or Sermo but as Krall notes, the pickings are with promotions, Krall reports. Many pharma marketing experts
are not edited or moderated. awareness, and promotion. Panel, which allow clients slim, since many drugmakers put predict that as DTC ads migrate
Each post includes an insight or to inform their message(s) a freeze on social media marketing • GlaxoSmithKline’s MyAlli offers online, and the FDA offers more
question, a poll, and a comment engaging PhYsicians: before launching a campaign. once the FDA began to focus on a community function it calls guidance for drugmakers on social
section. This allows physicians Proven social Media After determining the right the issue. “allicircles.” While the approach media marketing, pharmaceutical
to gather both qualitative and message set, Sermo works with Having said that, there are still harkens back to computing days companies will launch far more
interactions
quantitative feedback from its clients to create awareness some good ideas being tested. of old—it’s a modern version of robust social media offerings. But
colleagues both within and Market research about the topic through variety Here are Krall’s top choices for a basic threaded discussion—it until then, success stories may be
outside their specialty. This Because physicians on Sermo of promotional channels, pharma social media campaigns: still gets the job done, fostering hard to come by.l
model has driven nearly 50,000 are already collaborating online, including email, special highlight supportive
posts, 1 million comments and Sermo can provide fast, quality, areas within its community, • McNeil Pediatrics chose conversations
3.5 million votes. It also allows and cost-effective interactions sponsorships, and pages Facebook for its ADHD Moms and information
for “crowdsourcing” about with any group of physicians. You dedicated to a therapeutic area, site, which fosters both medical sharing among
the most talked about drugs, can target physicians by demo- topic, or drug (sponsorships/ and social discussion among users in a way
disease states, and therapies graphic criteria or match them pages coming soon!) participants. The page offers which also
– even new innovations. against a target list. Perhaps the To learn more about engaging educational information, advice, promotes trust in
biggest differentiator for Sermo physicians on Sermo visit guided community discussion, a the product. Not
the business Model: is that its physicians are already www.sermo.com/client. non-employee “Mom-bassador” surprisingly, the
how does it work? sharing honest and candid feed- tasked with writing up her site also offers
Sermo’s social media platform back with each other– and they experiences as a caregiver, and links to its page
allows Life Sciences Companies bring that same thoughtfulness to podcasts. When checked in on Facebook, its
(pharma, med device, biotech) their interactions with clients. mid-2010 the page had more Twitter account
to interact directly with its physi- Sermo’s market research than 11,000 fans.The site, which and YouTube,
cian community. Because there’s includes both quantitative and seems to be active, states in a but these seem
already an active group of MDs qualitative services. Clients few locations that it’s sponsored to be there to
7 | June 2010 June 2010 | 8

5. fiercepharma.com
The future of Pharma
advertising: dTc goes Social pating in a conversation whether Another reason why pharma com- created a community of parents them that will have a trickle-down
it’s specific to a disease state or panies are going this way is because who really do share information. effect to that pharmaceutical
Q& A with DJ eDgerton, co-founDer of phArmA
DigitAl mArke ting Agency, pixelS & pillS treatment in general. I think it’s the they see the potential in what we The trend is that patients are company and brand associated
responsibility of the pharmas to call “enlightened moderation.” You with that support mechanism. You
going to the Internet for third-party
participate in the conversation. can empower patients, caregivers endorsements in circles of influ- don’t necessarily have to pitch a
Also, when pharma companies and physicians with the platforms particular drug; all you
 FiercePharma: Why are are looking to put their finger on that they need to have real, mean- have to do is empower
pharmas using social media at the pulse of what’s going on out ingful dialogue and sharing. people to talk amongst
“When pharma companies are
all, given the regulatory risks there, there’s no better format themselves as a service
looking to put their finger on the
involved? than social media to reach people FiercePharma: What social to them because you
pulse of what’s going on out there,
suffering from diseases or health media techniques have you really care.
there’s no better format than social
DJE: Obviously, the regulations in conditions. You can’t go the bus seen that have proven to be The pharmaceutical
media to reach people suffering
place never have considered social stop and talk to another mom successful for pharma brand companies that people
from diseases or health conditions.”
media as a type of communication whose child suffers from MS. managers? believe actually care are
that would ever exist. Those people don’t exist in the the ones that will be
I think the knee-jerk reaction localized circle of influence, so it’s DJE: Sites that I think have successful. And social
is that if pharma companies and very hard to share some of the provided value include (Facebook- ence that they trust. If you can media’s not the be all and end all,
brands don’t participate, others will challenges involved. Social media based) ADHD Moms, which was create a community of like-minded but it is a wonderfully effective tool
participate on their behalf. The con- allows for some very strong bonds launched with the intent to provide individuals facing the same health- to give people the impression that
versation is happening regardless. to occur, and often they go offline real information to moms whose care challenges, you are inherently you actually care. Consumers can
Consumers in general are partici- as bonds mature. children have the disorder. This has going to create a bond among
continued on page 11
 Should [pharmas] actively avoid participation—even to the degree of  To date, Lilly has avoided significant interaction  Many non profit “disease advo-
monitoring—lest they uncover an adverse experience? Shouldn’t companies with healthcare professionals and patients about our cacy” groups which are primarily
embrace social media so that adverse experiences can be found with greater products in social media forums—largely because of or substantially funded by indus-
alacrity? Shouldn’t companies be rewarded for such behavior? If regulated a lack of clarity in understanding FDA’s expectations try have expanded the scope and
industry wants the FDA to be both regulator and colleague, then it’s not a leap as to how we could participate and comply with range of material and interactive
of faith to imagine that the FDA would like industry to be proactive in its search FDA requirements. media tools they have on the Web.
for new ways to surface adverse events. We did recently launch a blog on Medscape, writ- This is of great concern to us.
I know of one large pharmaceutical company whose policy is not to moni- ten by our U.S. medical team, to share information We have reached the conclusion
More tor social media sites because they don’t want to unearth adverse events. Is with physicians. Participants are allowed to post com- that FDA should consider regulat-
Views on this responsible? Is it even supportable? If this company received a call from a
reporter and was asked if they purposely avoid social media so as not to find
ments, either about our blog post or about each other’s
comments. That’s the essence of social media, after
ing portions of the content of the
Web sites of groups that get a
Pharma adverse experiences, would the truth set them free? Legally they may be in all—the ability to share information, experiences and substantial portion or majority of
Social compliance, but it wouldn’t look good on Page One or sound very good in front
of a congressional subcommittee. “In compliance” and “in the best interest of
opinions with others in the community. We are pre-
screening all comments, however, and declining to post
their funding from drug or device
companies.
Media the public health” must not be mutually exclusive propositions. any that mention a product.
Use — Peter J. Pitts, President, Center for Medicine in the Public Interest — Eli Lilly and Company
— steven Findlay, senior health
Policy analyst, Consumers union
9 | June 2010 June 2010 | 10

6. fiercepharma.com
continued from page 10 family with high choles- communicating with
terol will socialize. each other is chang-
see right through the sales pitch,
but they’ll embrace the community
Besides, tech-
nology is now
ing, and if you don’t
adopt your guide- fda Social Media Proposals whether existing rules can be
aspect if you support it in an hon- available—through lines correctly and Put Pharmas on notice stretched to cover regulation of
est and effective way. semantic filtration empower your social media, and if not, what regu-
By Anne Zieger
as well as building employees to do lations would best extend existing
FiercePharma: What pharma applications within the right thing, you drug and device standards to these
social media strategies have Facebook—to allow for run the risk of some new tools.
been less successful? the dialogue to happen unfortunate situations. Perhaps the most basic issue
but also weed out and flag the FDA faces is determining
DJE: One of the things to keep conversations that might be risky. FiercePharma: Finally, how is tra- which online communications
in mind is that the most effective One of the things pharmaceuti- ditional DTC advertising going from manufacturers, packers or
component of social media on, cal companies forget is that if you to be affected by social media? distributors should be regulated in
say, Facebook is the Wall post. provide real value exchange, con- Will it change? the first place.
It’s an immediate opportunity to sumers will agree to terms and For one thing, the agency is
have conversations on particular conditions that are often far more DJE: DTC advertising is going trying to figure out how much
subject matters. restrictive than what the common to change with regulation to the control such entities should exert
The problem is that under FDA consumer would agree to. If you point where it’s almost undoable.
guidelines the need to report back up those terms and condi- Nobody’s going to pay for three
adverse events creates such a tions with technology that monitors minutes to offer the necessary fair
no regulation prohibits
level of risk that most pharma- posts, you can provide an environ- balance that will be required. And
the use of certain types of
ceutical companies shut off that ment which allows people to have who wants to pay for five ads in a
media to promote drugs
functionality. healthy and compliant communica- magazine when one is brand-relat-
and medical devices.
tion without creating ed and the rest is only information
an enormous amount that goes behind it?
of risk. One of the big things that’s going
“Before moving in any direction at all,
And the upside to happen in the next 12 to 24 over their own content. Officials
you need to have in your corporate
potential is huge. months, if not sooner, is that digital are also trying to sort out whether
dna the willingness to change the way
With just some intel- will be driving DTC. As [a speaker drug- and devicemakers should
you talk to your consumers. Because
ligent tweaks to the at a conference] said, the only screen and respond to comments
the way people are communicating
consumer model, you place that real DTC belongs is on by the public, and if so, under
with each other is changing...”
can leverage social the Internet. Instead of it just being what circumstances. Not only
media so that you branded messaging to inform peo- that, the agency is mulling how
create a groundswell ple about a brand and what disease much companies involved with the
But in my opinion, that robs the of patient support and insight it treats, it’s going to be more along manufacturers of pharma products
audience of the entire reason that that goes a long way in develop- the lines of informing and educat-  Last November, the FDA let the The agency is starting pretty should control content, and even
they want to participate in the com- ing a relationship. The consumer ing people to a whole suite of other public—and more notably, drug- much from ground zero in its disclose their involvement.
munity. It’s kind of like throwing is going to know who was there things related to that drug. makers—know that it planned to efforts. Officials concede that Where do drugmakers stand on
a party and putting duct tape on when they needed them. My suggestion would be the issue regulations on how pharmas there’s no regulation specifically this issue? According to Johnson
everyone’s mouth. No one’s going On the other hand, not having most successful strategies for DTC could use social media. While the addressing Internet promotion & Johnson, pharmas should be
to go to that party. guidelines is a big mistake. Before will be the ones that are driven new regs should hit the street by separately from other types of pro- held responsible for content they
The reality is, nobody wants to moving in any direction at all, you by digital, not where digital is an the end of this year, that’s still a motion. What’s more, no regulation post on their own site or third-party
“friend” Lipitor, but people will join need to have in your corporate adjunct. Because the place where long time for pharma marketers prohibits the use of certain types sites, according to J&J presenters
a community that provides infor- DNA the willingness to change patients will be truly educated is not who are struggling to make their of media to promote drugs and Elizabeth Forminard and Philomena
mation and support so that people the way you talk to your consum- going to be a TV commercial or a campaigns meet existing offline medical devices.
with high cholesterol and who have ers. Because the way people are print ad, it’s going to be the web. l guidelines. The question for the FDA is continued on page 13
11 | June 2010 June 2010 | 12

7. fiercepharma.com
continued from page 12
McArthur, who spoke at the
November hearing. A drug-
adverse reaction reporting whether pharmas have an affirma-
maker should also disclose challenging in Social Media tive obligation to mine the web and
any material connection By Anne Zieger social media for adverse reaction
between itself and a con- reports. The FDA is mulling over this
tent provider, they said. issue, but hasn’t reached a conclu-
On the other hand, com-  For years, pharmas have been product, and party X says that sion. Not surprisingly, drugmakers
ments by the public are struggling to use promotional someone was killed by that prod- addressing a recent FDA meeting
another matter entirely. advertising on the web effectively, uct,” Kupchyk said. “The question on social media promotion emphati-
“Generally, user-generated as the medium is far more elastic is whether pharmas should monitor cally denied that they should be
content should not be con- than traditional product packag- [all comments to screen for this required to do such research.
sidered promotional labeling ing or even television advertising. type]. And if they’re not monitor- With the stakes so high, should
or advertising,” the J&J While most have managed to ing comments, do they need to pharmas avoid social media until
reps argued. adapt, a few have received FDA respond to them at all? Do they the FDA offers ironclad guidance
Another concern for warnings over content that the need to have a disclaimer on a on the adverse event issue? Not
the FDA is how to make agency perceived as lacking risk- page offering consumers a phone necessarily, as long as they do it
sure pharmas provide fair, benefit balance. number to call if they’ve experi- carefully, argues Kalah Auchincloss,
balanced and accurate The game has gotten more enced adverse events?” an associate with the D.C. office of
information in new media complex with the emergence of Then there’s the question of law firm Foley Hoag LLP.
channels (such as Twitter) social media. Not only do pharmas “I’d advise any company to turn
that don’t allow for deeper have to meet FDA promotional off the comment feature of inter-
messages. While websites guidelines, they also have to figure While most [pharmas] active websites, but I don’t think
may offer plenty of space out how to deal with adverse event have managed to adapt, pharmas should be afraid to use
to present complete drug reports. What’s more, the problem a few have received fda social media, if they use it in a way
information, a Facebook fan is likely to grow more complex as warnings over content that that complies with the law,” she
page may not. social media networks emerge, the agency perceived as said. “Just be smart about it. Use
Yet another question the agency label uses of those drugs. there will be serious consequences merge and add new features. lacking risk-benefit balance. your intuition, and if something feels
is examining is the use of links in Some observers consider the if FDA allows them to use the full At the moment, drugmakers like it’s wrong, check it out.” l
pharma social media marketing. FDA’s battery of questions to be array of social media.” still aren’t sure how to cope with
While drugmakers are not allowed thorough, but some critics still What’s more, the FDA has adverse events reported on the
to promote drugs for unapproved think the agency hasn’t covered bypassed an issue Chester sees web, much less on Facebook,
purposes, the Internet and social all of its bases. “There’s more as critical. “Drugmakers never talk within tweets, in articles targeted
about the social media monitoring by social bookmarking sites, or
they may be deploying,” he notes. content on blogs.
“I think pharmas thought they The FDA’s current position is
While drugmakers are not allowed to promote drugs for could pull the wool over the Com- that pharmaceutical companies
unapproved purposes, the internet and social media seem mission’s eyes.” should simply follow existing guide-
to be providing them with a loophole. Chester, who expects to meet lines for other media when they go
with top FDA officials soon, will online. However, that leaves ques-
urge them to focus more on tions unanswered, said Areta L.
media seem to be providing them than meets the eye here,” said consumer data collection through Kupchyk, a DC-based partner in the
with a loophole. At present, some Jeff Chester, executive director of social media. “The agency didn’t life science health industry group of
pharmas provide links from brand- the Center for Digital Democracy. get into privacy concerns this law firm ReedSmith.
ed sites to other information sites “Pharmas have presented social time,” Chester said. “I think it failed “Let’s say there’s a website
that may contain information on off- media as mom and apple pie, but to do due diligence.” l talking about the use of a specific
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