I had a chance to watch parts of a Google+ hangout discussing the latest FDA social media guidance with David Harlow from Health Blawg. I’ve had a chance to work on a number of things with David and he’s a really smart guy that’s on top of a lot of the regulations that affect healthcare. I guess that’s a feature of being a healthcare lawyer. For those who missed it, you can check out the full video interview with David below:
For those who prefer the cliff notes version, David published some bullet points on his blog that do a great job summarizing the main points and key takeaways:
- The draft guidance makes use of Twitter and platforms like Google Ads extremely unattractive, because the vast majority of the “real estate” must be given over to brand and generic names, indications for use, benefits, risks, and a link to fuller information about risks.
- The FDA addressed itself to short-form communication without considering the way in which it is used most effectively – not as a canvas for ads, but as a forum for conversation.
- Unbranded tweetchats, Facebook pages, and the like were OK before the draft guidance was issued, and they still are.
- The correction of misinformation guidance lowers the regulatory bar for corrections (vs. marketing messages that must meet higher standards and may be subject to pre-review).
- The misinformation guidance does not require a drug or device manufacturer to address all misinformation online about its products. Corrections must be focused responses to what others put out there on line, and should link to fuller information where appropriate, but corrections should not include or link to promotional material.
- The misinformation guidance delineates an area of opportunity for drug and device manufacturers.
You can read more on his blog post including someone getting in trouble for liking a patient’s status. Think about that for a minute. Is it any wonder that pharma’s been really careful with social media?