Leveraging Social Media in the Pharmaceutical Industry - Innovation and Marketing in the Pharmaceutical Industry - page 473

The external barrier for drug companies to embrace social media is the high
regulation standard in this industry. Pharmaceutical companies are required to
report to the FDA any monitored social media conversation concerning possible or
potential adverse outcomes related to their drugs. Furthermore, their direct com-
munication to patients on their drugs is controlled. As the general public increas-
ingly trusts social media, engaging patients without crossing FDA regulations is a
challenge unique to pharmaceutical marketers. It is more of a puzzle for pharmaceu-
tical marketers when there is a lack of clear guidelines. According to the eyeonfda.
com posted on May 31 2011, the FDA has repeatedly delayed issuing any guidance
on the Internet and social media. “In October, 1996, the agency held its first public
meeting on the regulation of the Internet and the Promotion of Medical Products.
In March 2009, they said it isn't the medium, it is the message. In November 2009,
they did the same 1996 meeting over again, only this time throwing in social media
and targeting the end of 2010 for the issuance of a draft guidance. It didn't happen.
Then the end of the first quarter for a guidance. It didn't happen.”
Frustrated by FDA inaction on guidance for digital marketing and social media,
industry players such as Merck, Roche, AstraZeneca, Lilly, Sanofi, and
GlaxoSmithKline (GSK), Google, Epocrates and HealthCentral and agencies such
as Edelman and Digitas Health are forming a nonprofit organization called the
Digital Health Coalition that aims to develop an industry consensus on marketing
via social and web media (Arnold 2011 ). The key unresolved issues for which mar-
keters await FDA guidance surround adverse effects and off-label usage. It is unclear
that whether pharmaceutical companies should be held responsible for third-party
claims about a drug's risks or benefits on outlets like Facebook and Wikipedia.
These problems could be mitigated by filtering or disabling commenting functions
on social outlets. However, to utilize major social media like Facebook, drug com-
panies have no control over the functionality of the medium. Facebook previously
allowed pharmaceutical brands to disable commenting on their Facebook page that
would avoid patients introducing off-label usage. However, starting June 2, 2011 ,
Facebook no longer allows new pharmaceutical pages to disable commenting on the
content their page shares with people on Facebook. For existing branded pages,
removing commenting functionality may continue to be allowed subject to Facebook's
approval (Thomaselli 2011 ).
There are some other unresolved practical issues involving basic online proce-
dures such as patient registration. Other practical questions include: How can phar-
maceutical marketers embrace social outlets such as Twitter and Google blogs and
sufficiently explain a drug's risks within the bounds of the 140-characters for a
tweet or roughly two lines of Google ads' text?

16.2.4 Social Media Use by Pharmaceutical Firms

Despite the challenges of social media in the pharmaceutical industry, several firms
have used social media to expand their social share. Baxa Corporation, a developer of