Gene Y. Miller | Cadient, a Cognizant Company
Since the first Food and Drug Administration (FDA) hearings about Social Media in 2009, clarification on proper use and the overall comfort level surrounding the use of social channels for pharmaceutical marketing has been gradual. Now, half-way through the 2010s, marketers and the FDA are facing a new set of marketing technology challenges, driven by the explosion of mobile devices, along with an increasing reliance on responsive web design to proportion web experiences on-the-fly according to screen-size.
While the core principles of providing clear labeling and balance will remain unchanged, new guidelines will – eventually – need to come to terms with an Internet experience that is increasingly fragmented, mobile, and multi-screened. This is especially true when dealing with “microblogging” platforms, such as Twitter, and paid search tools.
So why should pharmaceutical marketers care about this dramatic change in media consumption? Quite simply, because more patients and healthcare professionals are relying on these social and mobile platforms to solve their healthcare challenges than ever before. According to the latest Pew Research Center survey, 52 percent of smartphone owners have used their phone to look up health or medical information, and 19 percent of them have downloaded an app.
Bottom line: Pharmaceutical marketers need to engage with their audiences on their terms.
Guidelines for Microblogging Platforms
For now, we must look to the most recent 2014 FDA Draft Guidance for Internet/Social Media Platforms with Character Space Limitations which focuses specifically on the use of online microblogging platforms such as Twitter, as well as online paid search of sponsored links on engines such as Google, Yahoo or Bing. The overall goal of the guidance is to aid firms in communicating risk and benefit information in product promotion using platforms with character limits.
It’s important to note that the FDA’s Draft Guidance literature makes it clear that the guidance does not apply to more “traditional” channels such as websites, webpages on social media platforms, and web banners. It also doesn’t directly apply to responsive web design.
However, when taking into consideration the character limitations of Twitter, paid search, etc., there is a chance that the platform may not allow meaningful, balanced use – especially for products with complicated labels or serious risks. Due to these factors, pharmaceutical marketers may find it impossible to take messaging to these new channels – regardless of the fact that patients and Internet users are moving to a richer, real-time web experience.
While it is important to take all of the above into account when considering marketing on microblogging platforms, the FDA does offer some thoughtful and very specific guidance surrounding several major concerns that can be helpful to pharmaceutical marketers. They also assist with many of the nettlesome issues that #digitalhealth and #ePharma marketers have been grappling with for several years. Pharmaceutical marketers should closely consider the following points:
• The message should have a comparable balance of risk and benefit, regardless of character space constraints: The benefit should be accurate, not misleading and factual, risk should be part of each communication, and symbols (such as &), punctuation marks and scientific abbreviations can be used to help reduce space constraints.
• The primary link should be provided for more complete information about risk: The primary link destination should provide comprehensive risk information about the product. The secondary link and destination can be considered along with the primary link. In addition, links should indicate topic of destination (for example, www.nofocus.com/risk). The destination page should have the brand and established name together with dosage form/quantitative ingredient information (logo lockup).
• A decision to not use a platform due to lack of balanced content should be considered if balance cannot be achieved: The complexity of the indication and side effects should be considered and the most serious risks should be included as a baseline.
Three Simple Steps to Create an FDA Approved Tweet
Following careful consideration of the aforementioned points, creating short-form messaging on platforms like Twitter can still be intimidating. As an example of creating this type of short-form messaging, we’ve broken down the requirements to help create a 140-character-limit tweet that is in accordance with FDA guidelines in three simple steps:
1) Include the Benefit Information: Start by typing in the benefits of the product keeping in mind that symbols can be used to help with character constraints.
2) Communicate Risk: Next, include information about the most serious risk of the product, along with a direct hyperlink to a more complete list of risk information.
3) Add the Name: Finally, add in the full FDA approved product name.
Pharmaceutical Marketers Must Engage on Their Audiences’ Terms
As we have seen over the last few years, the FDA has moved at relatively slow but deliberate pace in addressing this incredibly fast-moving mobile Internet revolution. Pharmaceutical marketers have an abundance of guidance, warning letter learnings and live engagement examples to move forward with social engagement.
With more than 500 million tweets being generated daily and new targeted online advertising options surfacing on a regular basis, it is clear that short-form messaging and advertising is going to remain a major fixture of the media landscape for the foreseeable future.
As such, it will be important to prepare for even more marketing technology changes over the coming year, as well as ensuring that pharmaceutical marketing teams are ready to start engaging with their audiences – on their terms.