Last summer (2014) the FDA released its latest Internet and Social Media guidance for Pharma and med-tech companies. If you haven’t read it yet, have a look here:
With the rise and use of social media across all industries, med-tech was destined to adopt its use. I believe this is mostly due to social media’s prevalence for customer engagement and relatively cheap way for reaching audiences.
The FDA guidance explains it was published to illustrate the agency’s thinking on the communication of benefit and risk information on mediums such as social and online media. The overall suggestions and illustration of what the FDA shares is food for thought for any health care organization or marketing professional working in health care. Below is my attempt at summarizing the guidance for anyone interested.
In the U.S. the FDA generally recognizes two types of labeling; that which is required labeling (think labeling for product approvals) and promotional labeling (subsequent marketing materials/labeling). When promoting products online the agency recommends the following: 1) Be truthful and non-misleading, 2) When making a claim about a product, indicate the use and risk of the specific product. 3) Make labeling easily available when discussed. 4) Include risk information and intended use when advertising a drug. If the name of the product is mentioned as a “reminder” promotional, instead of how the product is used, it’s then excluded from this rule. 5) Fairly present benefits and risk information of drug advertisements. 6) Prominently reference risk information of suggested uses.
The FDA asks firms to consider carefully whether or not they can accurately meet the guidelines when promoting products and making product claims on social media. The document then subsequently goes through each of the guidelines mentioned above with generic samples of how to disclose risk information within brackets [ ], which includes how to incorporate URLs for additional product information. The main takeaway here is to be succinct, truthful and informational with your product promotions where a claim is being marketed.
For social media professionals working in the medical space it’s always important to inform your customers to consult their medical practitioner for medical related inquiries and not social media! Furthermore, clearly state your right to remove abusive language or information not pertaining to the community. This helps keep the conversations relevant to those visiting your communities. Lastly, include fellow employees and emphasize the need to act truthfully when on social media, especially when engaging customers, fellow colleagues, clients, business partners, and the public.
I personally believe med-tech companies should not be intimidated by social media. We should all view it as an opportunity to shine with whatever specialty your organization brings to the table. Empower employees to embrace change and new tools for the growth of your brand and the evolution of your customers’ experiences.
Frankly Speaking: Implement a checks and balances with key stakeholders so your content is vetted through appropriate processes.