Marketing by the pharmaceutical industry is tightly controlled and closely monitored by federal regulators, and with good reason.
But it seems that the paradigm shift created by social media as a channel for communicating with consumers has stumped pharma's government overseer, the Food and Drug Administration, at least for the time being.
While detailed guidelines govern other forms of drug marketing, an FDA social media policy has failed to materialize. The FDA held public meetings on the issue in November 2009 and promised guidelines in 2010. But they missed their own deadline and now say they're shooting for Q1 2011.
Key to FDA requirements is what's known as "fair balance." In other words, drug makers need to give roughly as much weight to communicating the risks and side effects of a treatment as they do to the benefits. Abiding by fair balance produces the television ads we're all familiar with where beautiful, reassuring images are jarringly coupled with a voice-over warning of potential side-effects.
The challenge presented to drug makers -- and the FDA -- is how to achieve fair balance in a 140-character tweet, for example.
I attended the 10th annual ePharma Connect conference in New York a couple of weeks ago and listened to a presentation by Thomas Abrams, director of the FDA's Division of Drug Marketing, Advertising and Communications. He acknowledged that developing an effective social media policy for the drug industry is "not easy."
He also intimated that the FDA may not provide rules on specific platforms, like Youtube, Facebook or Twitter, but instead could apply its existing content guidelines to these new tools. Regulators have in the past allowed marketers some flexibility in achieving fair balance given the limitations of, say, a banner ad.
While the FDA struggles with its guidance for drug makers, I learned this week that even the Girl Scouts have a social media policy governing the sales of their ubiquitous cookies. (Fair balance warning: They're addictive and side effects could include an expanding waistline.)
My 5-year-old daughter doesn't have a Facebook page ... yet. She's more into the iPhone sensation, "Angry Birds," right now. But if she did have a Facebook page, she couldn't use it to sell Girl Scout cookies. Only "girls who are 13 or older may also use social networking sites such as Facebook, LinkedIn and Twitter to sell cookies. However, they must follow the council and GSUSA guidelines on girlscounts.org/cookies." Selling cookies on Craigslist or eBay is prohibited. And while using e-mail, text messages and Cookie Club (the Girl Scouts' secure website) to inform and take orders from friends and family is allowed, sending blast e-mails is not.
Meanwhile, pharmaceutical companies are moving ahead with social-media-based initiatives, albeit cautiously. On Feb. 16, Astra Zeneca hosted the first-ever pharma-sponsered Twitter chat, #rxsave, to have a conversation directly with consumers.
Tony Jewel, editor of Astra Zeneca's Health Connection blog, wrote this to John Mack, author of the Pharma Marketing blog: "We decided to sponsor this discussion for a simple reason: We believe it is important to spread the word about the availability of our prescription savings programs. Today, Twitter and other social media channels are invaluable tools to do so. We will, however, be limited as to what we can respond to during the chat. For example, we will be unable to discuss specific medicines and/or diseases on this chat to ensure all communications are appropriate and meet current regulations."
According to Mack, the Twitter chat was a success, though he speculated that the FDA might have been lurking and a warning letter could very well be on the way.
It'll take some time, and maybe some missteps, before it's clear how drug makers can use social media. Some direction from the FDA will be a good first step.
Schmid is the managing partner of Cook + Schmid, a San Diego-based marketing and public relations firm. He can be reached at firstname.lastname@example.org. Follow him on Twitter @jschmidpr, or read his blog at cookandschmid.com.