The Regulator’s Dilemma – A Look at the FDA & Social Media

Let’s start with a simple question.    Is it best to ensure that the people with the most expertise related to a product or service have the ability to tell their story, answer questions and share their knowledge online or is it better to keep these same experts on the sidelines and let a random assortment of people try to fill the vacuum, ranging from well-meaning citizens to spammers?

The answer is common sense.  We want to hear from the experts.  It helps us make the best and most informed decisions in our lives.

If we think about the development of a medicine, I know I want to hear from the people who have dedicated their working lives to creating a drug for a decade or more.  I want to hear physicians who have participated in the clinical trials discuss their experience and I want to hear from the people who take the medicine or suffer from the disease.  I want to hear from the skeptics as well.  Even better, I want to hear all of them talking, sharing and debating together online. 

The wisdom of crowds applies to how we learn online.  We’re better off when transparency and open communications is the rule, not the exception.  We learn from our peers and, as we know, peers have a profound influence on our decisions.

And herein lies the dilemma for regulators, of which I actually have great empathy.  Leaders within regulatory bodies, ranging from the FDA to the SEC to the EPA, all feel compelled to come up with solutions that, not surprisingly, involve lots of restrictions on what can be done or said.  However, with each restriction, we have less content, less knowledge, less debate and less of a chance to know something that makes a difference for each of us. 

The issue for regulators, as it relates to social media, is quite simple.  If you try to regulate how companies do their business online, you create other unintended consequences.  Remember that principle from economics?  It applies in social media as well. 

Let’s take the healthcare industry, as an example.  Right now, the experts are truly on the sidelines, in most cases.  As a result, approximately 90% of all blog posts related to medicines are currently spam.  The majority of informative sources found on a first screen during a Google search are unregulated sources. Sploggers are proliferating to fill the gap and drive people to their websites, often for less than optimal solutions for health problems.  By the way, “less than optimal” is being kind.  Too many of these sites are simply not acceptable and are actually directing people to make bad choices related to their health. 

Oops. 

But not a surprise.  Markets, like nature, abhor a vacuum.  If you keep experts on the sidelines, the river still runneth with content that may or may not be of help.  Said another way, we create a greater health risk by not allowing industry to participate more freely online. 

It is with this mindset that I found it intriguing that when Tom Abrams, head of the FDA’s Division of  Drug Marketing, Advertising and Communications, spoke at an ePharma Summit last week, he received some less than optimal coverage due to the belief  that he has not put out clear guidelines for the pharmaceutical industry yet on social media.   Kudos to Tom for taking time to study social media, think through how it works and to move with caution on how the FDA may eventually provide guidance. 

The challenge for Tom and for regulators like Tom worldwide in the healthcare industry is to improve patient safety and knowledge by enabling experts to share their learning’s in ways that will help us all.   For better or worse, it’s not as simple as providing guidance and moving on.   It’s not about Twitter or Facebook or YouTube.  Tom’s right.

It’s about a newly diagnosed cancer patient finding the best available information in real-time.  It’s about caregivers being able to get the best advice for their parents at midnight.  It’s about all of us being able to search and feel comfortable that the information at our fingertips can be trusted.  

Our health is too important.  And as a result, regulations for social media are also too important to rush.

That being said, with each passing day, our online world is filled with hundreds of thousands of spam blog sand other tricks put out by folks with the wrong intent.  And millions of people search for information that they hope will give them some answers to important issues they are grappling with each day. 

I hope Tom and his team take the time they need to determine what guidance will protect and improve the health of our nation and serve as a model for many countries debating our new online world.    Patients are waiting…for the right information from the most informed people on earth. I hope they can find each other online with time. 

All the best, Bob

PS/I worked in the pharmaceutical industry for years and I do consult with a range of healthcare clients today in pharma, biotech and medical devices.

By: Bob Pearson

Bob is the President of W2O Group, an independent network of digital communications and marketing companies. He is an author, frequent speaker and instructor for Rutgers center for management development. After the success of his book Pre-Commerce, Bob is currently working on a new book on the future of media titled Storytizing that will be available in 2014. Prior to W2O Group, Bob worked as VP of Communities and Conversations at Dell to develop the Fortune 500’s first global social media function -- an industry-leading approach to the use of social media, as highlighted in the best seller, GroundSwell. Before Dell, Bob was Head of Global Corporate Communications and Head of Global Pharma Communications at Novartis Pharmaceuticals in Basel, Switzerland, where he served on the Pharma Executive Committee. He also serves on a variety of Boards in health and technology. Highlights include serving as an original member of the P&G digital advisory board and being appointed by the Governor of Texas to serve as chair and vice chair of the emerging technology fund for the State of Texas.

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