A little more than a year ago, in advance of a much-hyped public U.S. Food and Drug Administration meeting on social media**, I pointed out five myths about that meeting and the prospect of dramatic agency action. Now, almost a year later, the FDA and social media is again a hot topic, as companies and industry watchers look to see if the agency will make good on vague promises to roll out new rules by the end of the year. (For a thoughtful overview, see this NEJM piece from last month.)
But now, as I did then, I am still skeptical that FDA action will dramatically re-shape the landscape. So in the spirit of the original post, I’d like to throw out five more myths in advance of FDA action.
Myth #1: Social Media Uncertainty Will be Vanquished. The FDA rules, when they come, will be labeled “draft” and those rules can — and will — change before they are made “final.” And so while the rules will have a uninhibiting effect on social media (see Myth #4), there will still lurk the idea that the draft rules may evolve in response to new information or particularly brilliant or worrisome initiatives that hew to the letter of the draft guidelines.
Myth #2: There Will be Clear Rules for YouTube or Twitter or [Fill in the Blank]. The agency, so far, has made a big deal about emphasizing that they really don’t care how messages are transmitted — by traditional advertising, by social media, by press release — what they care about is that the messages abide by the agency’s standards. So while some universal aspects of social media may be addressed (John Mack of the Pharma Marketing Blog wisely predicts that linking behavior and adverse events may be the first to receive attention), don’t expect to see any effort to tackle granular issues, such as the use of the “retweet” or whether YouTube comments should be enabled.
Myth #3: Branded Social Media Will be ‘De-Risked.’ Just because the FDA OKs social media, broadly, doesn’t mean that there won’t remain serious risks involved in pushing the boundaries. Take television advertising, as an example: despite hundreds of pages of documentation and the better part of two decades of case history, the agency is still finding flaws in existing efforts. Guidelines could mean that scrutiny of social networks increases, not decreases.
Myth #4: New Rules Will Have an Immediate and Practical Impact. I won’t argue against the idea that the new rules will spur greater use of social media in branded communication, but any renaissance in the use of those tools by pharma will be due as much to the psychology of communicators reacting to a philosophical green light from the FDA as any specifics set forth in the draft rules.
Myth #5: Guidelines Will Lead to an Explosion of Branded Social Media. We’re still in the early days of social media, and it’s not entirely obvious what, exactly, patients want from biopharmaceutical companies. Even with clearer rules, it’s possible that branded, industry-sponsored content will be less important to patients than other, less-branded content, such as online patient and provide education, disease awareness, economic assistance programs and the like.
Given those myths — and the realities that will be revealed as the FDA rolls out its policies — it’s worth noting, briefly, what companies should be doing: establishing broad, thoughtful and actionable monitoring efforts; fully leveraging social media in corporate and unbranded activities (with transparency); and engaging with online and offline influencers. Those aren’t complex concepts, though, as with so much in business, success is primarily a matter of execution. Have questions? We have a whole stable of folks ready to help out.
** My colleagues at WCG presented some interesting analyses at that meeting. Worth checking out, if you haven’t seen already.