CommonSense Blog

Some non-TEDMED News: Are we getting closer to healthcare social media guidelines?

By Adam P. Silverstein | Apr 18, 2013

If you work in the health care space, you know that almost every major health thinker and expert is at, watching or engaged with TEDMED. Your Twitter steam is probably working overtime, including a guy who knows about working overtime, Richard Simmons.

But I digress. While great ideas will surely emerge from TEDMED, I think there’s something unrelated, and while not as sexy as TEDMED, it’s as important. Real movement on social media guidelines.

This week, Tom Abrams, who heads the FDA Office of Prescription Drug Promotion and its efforts to create social media guidance, provided some of the best updates yet to Pharmalot on when we can expect it.

Since 2009, when they first were discussed, healthcare social media guidelines have really been like the Loch Ness Monster. Each time you were sure you’d seen them, or at least caught a glimpse, they rose vaguely to the surface, filled you with hope – and probably fear – and then disappeared quickly into the depths.

Of course, pharmaceutical and biotech companies haven’t just been waiting and hoping. They’ve made great, responsible efforts to establish a social media presence, and I think stakeholders from physicians to advocacy groups to patients have all benefited tremendously. But as my colleague Brian Reid has written about before, it’s the smaller companies who are still struggling to jump into murky waters without firm guidance.

As we wait for the final guidance, expected in 2014, here are some of my brief reactions to Abrams’s comments along with some questions I would have asked

Abrams says FDA is looking at how to promote and fulfill regulatory requirements in venues with space limitations. This applies mostly to Twitter, and I’m glad to see the focus on it.

  • What I didn’t see is any thoughts on how fair balance will be communicated beyond vague descriptions of the “one click” rule. What else is being considered? Could a company post a follow-up tweet with fair balance? Is that enough?
  • Also, what will a company’s responsibility be to reply to a user who’s tweeted about an adverse event? Will one reply to that user be sufficient? What will constitute full due diligence?

Regarding Facebook, Abrams was somewhat evasive when it comes to a key issue, whether a “like” on the channel is equal to a product endorsement.

  • Specific guidance on this is crucial if companies are to keep engaging on these channels and provide patients with accurate information about a product.
  • If the FDA is going to ramp up enforcement of this social channel, I’d like to see a stronger commitment from them to have comprehensive guidance on Facebook use

We’ll have to keep waiting for these guidelines, but this seems like one of the bigger steps yet. I’d love to know, what questions would you want to ask the FDA as they consider social media guidelines?