January 20, 2016 | by Sarah Massey, M.Sc.
While social media has undoubtedly become an integral part of many people’s daily lives, the pharmaceutical industry is lagging when it comes to harnessing the potential power of Twitter and Instagram. Pharma marketers have historically been much more comfortable with the one-sided conversation of a direct-to-consumer (DTC) ad, but as the industry moves more and more towards patient-centricity, it is becoming necessary for drugmakers to increase engagement with their stakeholders.
Admittedly, there are a number of roadblocks preventing pharmaceutical companies from taking full advantage of social media. As a highly-regulated industry, pharmaceutical marketers face strict Food and Drug Administration (FDA) guidelines when writing a post, or engaging with followers. If pharmaceuticals are promoted in a way that violated these stipulations, the company could receive an FDA Warning Letter.
Though there are a number of issues that impede pharmaceutical companies from making full use of social media platforms, we identified the top 3 limiting factors to social media marketing today. While the FDA regulations serve to complicate the pharmaceutical industry’s social media presence, the marketing potential of these sites is too immense to ignore.
Twitter’s Character Limitation
Recently, a leak announced that Twitter is planning to increase the current 140-character limitation to as much as 10,000. This came as welcome news to pharma marketers as the FDA’s rules on risk disclosure when promoting a pharmaceutical prevent them from promoting drugs on the popular social media site.
Doug Weinbrenner, the senior director of social media at marketing company Intouch Solutions said, “[Twitter has been] the least used and least recommended platform,” for pharmaceutical marketing firms. He went on to say, “Twitter revolutionizing the platform is probably one of the biggest things that happened in social media over the last year, and there's a considerable amount of interest in us being at the forefront of social pharma.”
In 2014, the Center for Drug Evaluation and Research – a branch of the FDA – released guidelines for social media posts aimed at promoting prescription drugs and medical devices. The agency’s regulations state that both benefit and risk information for the promoted product must be equally presented and the indicated use of the product must be presented in a way that is not misleading.
These stipulations for social media posts can be difficult to follow – especially with a character limitation of 140 or less. While the news of a much larger character limit – potentially over 7,000 percent larger – is a welcomed change for pharma marketers, some are wondering how Twitter will maintain the current look and feel of the site while incorporating larger posts.
According to some insiders, the social media platform may show a segment of a post while requiring readers to click in order to view the full text. Unfortunately for pharma marketers, this would put them right back where they started, considering the FDA’s opposition to the “one-click rule.” According to the FDA, marketers must present all necessary safety and side-effect information in a single post, without requiring the user to click to read more. While Twitter has the potential to be a valuable tool for engaging with patients and consumers, the current platform is incompatible with the regulations surrounding pharmaceutical promotions.
Celebrity Endorsements and Misrepresentation
Last year, Canadian drugmaker Duchesnay, received a warning letter from the FDA after sponsoring a promotional Instagram post by Kim Kardashian, in support of the company’s morning sickness medication, Diclegis. While the post included a link to the risks associated with taking the drug – along with a shot of Kardashian holding up the bottle like a spokesmodel – the “one-click rule” was once again shot down by the FDA.
“The social media post is false or misleading in that it presents efficacy claims for Diclegis, but fails to communicate any risk information associated with its use and it omits material facts,” said the warning letter sent to Duchesnay. “These violations are concerning from a public health perspective because they suggest that DICLEGIS is safer than has been demonstrated.”
Duchesnay was given two options: stop misbranding the pharmaceutical by removing Kardashian’s endorsement post, or stop distributing the drug in the US altogether. Kardashian updated the post to include indicated use, limitations of use, and important safety information of Diclegis, in order to comply with FDA regulations.
With over 57 million followers on Instagram, Kim Kardashian could be a very strategic partner for Duchesnay. Despite the reach of Kardashian’s posts, it’s still a less-than-ideal situation for pharma marketers, who are unable to have an organic interaction with potential patients.
Conversations With Stakeholders Limited
The FDA regulations for pharmaceutical marketing on social media serve to remove the most valuable aspect of the medium: the social aspect. While complying with regulations requiring marketers to list paragraphs-worth of important – but admittedly dry – safety information, companies lose the ability to have genuine interactions with stakeholders.
Pharmaceutical companies also often have trouble with platforms that allow the public to post comments. As regulators require that pharmaceutical companies report all possible adverse reactions to drugs – including those disclosed in the comment section of a post on social media – companies are often unwilling to devote resources to moderating these comments and ensuring compliance.
In some instances, pharmaceutical companies are also responsible for correcting misinformation regarding a drug or medical device that has been posted on the web. Corrective action is not just required for misinformation that puts the product in a negative light, it also applies to posted comments that confer a positive – but unsubstantiated – claim on the product. If pharma marketers correct one piece of misinformation over the other, they are not in compliance with the FDA’s draft guidance.
If these three stumbling blocks weren’t enough to keep pharmaceutical marketers away from social media, the recent call for a total ban on direct-to-consumer (DTC) advertising would certainly present an insurmountable hurtle, if approved.
What do you think about pharma’s social media presence? Share your opinions in the comment section below!
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Keywords: Pharmaceutical Marketing, Direct-To-Consumer, Social Media Promotion
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