Social Butterflies or Wallflowers?
Social media is transforming the world. It’s connecting people by transcending geography, life experiences and cultural divides. We’ve seen how a simple Twitter conversation about breast cancer turned into #BCSM, a global community of information, support and empowerment.
Even the National Cancer Institute holds regular Twitter conversations connecting the public to the front lines of cancer research. Importantly, social media also gives the patients we serve a direct connection with us and other companies.
As one of the world’s largest makers of medicines, we have unique insight into the latest treatments for serious diseases like cancer, arthritis and lung disease. At the same time, because we are part of a regulated and complex industry, our full participation on certain topics remains somewhat limited.
[The industry] shouldn’t bemoan regulations and shy away from social media, but rather embrace them and try to contribute in a meaningful way.
Our Social Boundaries
In a much awaited and progressive move, the FDA released draft guidance on how companies should engage on social media for the direct marketing of medicines. These guidelines are a necessary first step to ensure fair and balanced practices across the industry.
One focus area is about how to use a medicine’s brand name across social channels. The FDA’s view is that the brand name of a medicine — the name most people are familiar with — is a form of marketing, and therefore subject to regulation.
Let’s take a quick look at how that and other regulations affect what we can or cannot do on our social platforms. Take Twitter as a representative example.
Whenever we reference the brand name of a medicine, we need to include an appropriate reference to safety. So for example, when using Twitter — where all messages are limited to 140 characters — the FDA guidance notes that we need to include the brand name, scientific name and serious side effects. The hypothetical example they give is for a fictitious medicine called NoFocus:
Because many of our medicines are for serious and life-threatening diseases, we can’t include the full safety information within the 140-character limit. So, even if the Twitter community wants to have a conversation, we can’t join them there.
If someone is having problems accessing our medicines, we can refer them to our access team, called Access Solutions, but we can’t have a public dialogue about a specific medicine.
When it comes to our presence on the web, our corporate or scientific communications must be at at least “two clicks apart” from “branded” information about medicines. This is challenging in a world where Google has made everything one click away. Nevertheless, we acknowledge and understand why these rules exist and we follow them.
Thinking Inside the Box
So the industry is left with two possible ways to respond to the regulatory situation: Stop trying, or think creatively to come up with solutions. Here’s what that looks like for us:
- First, we talk about science. That’s at the heart of what we do, and it’s important that we share inspiring science in fun, interesting ways. Fostering curiosity and dialogue about science helps patients as well as companies — it might even help inspire someone to become a scientist or doctor.
- Also, we share our views on topics beyond any particular medicine, like regulatory science, clinical trials and patient empowerment.
- We try, as much as we can, to be creative in how we use digital channels to tell our stories. For ASCO 2015, we’ll be experimenting with new forms of digital and social on topics we think are most relevant to the ASCO community. We expect to learn from the reactions we receive, and those insights will guide us as we continue to explore what is possible.
As an industry, we must work with the FDA to figure out the most responsible ways to directly engage. We shouldn’t bemoan regulations and shy away from social media, but rather embrace them and try to contribute in a meaningful way.
One potential area where we need more dialogue is around the fact that not all social conversations are the same. The intent behind direct marketing is very different from a two-way conversation or the mention of a medicine. Should they be regulated differently? It’s an interesting question. The draft FDA guidance has provided a great start to this conversation.
These and other issues need further exploration. Collaboration between industry and regulatory authorities will be key as we navigate the frontiers of social media in healthcare. This topic calls for active participation from all — there’s no room for any of us to be wallflowers.