Many Pharma companies have expressed a reluctance or nervousness towards engaging in social media activities. There have been several reasons for this reluctance and we are slowly seeing a resolution to some of these issues. Firstly, there were concerns over the broadcasting of marketing messages to the public. The answer to this has been simple: the guidelines for communication through traditional forms of marketing still stand. In Europe this means no communication of prescription drugs can be aimed at the public. However general company messages and certain over-the-counter (OTC) or non-prescription drug communication is permissible. As a result, companies brave enough to have a social media presence have done so by having a company-based page and posting about their philanthropic efforts, what it’s like to work there and unbiased articles about their company.
Another issue regarded User Generated Content (UCG) and general engagement with users. What content is the Pharma company responsible for and what can they engage with the public about. Recently released guidelines from the FDA suggest that companies are responsible for any content published by the company itself, a representative of that company, or any content that they have influence over or published by an individual they have influence over.
Possibly the most talked about, and specific issue is that of Adverse Event (AE)reporting. Pharma companies were concerned about what mentions of adverse events needed to be reported and by creating a public profile, were they opening themselves up to a huge increase of adverse events which would need to be reported to the relevant statutory medical body. Reportable adverse events require an identifiable patient, an identifiable reporter, a suspect drug and an adverse experience or fatality suspected from the suspect drug.
The solutions to these issues were simple in idea but potentially difficult to execute. Clear social procedures and policies need to be implemented for engagement. Transparent rules need to be implemented for company engagement, representative communications and employee communications. Also policies regarding what can be discussed on a company’s page and the company’s method for reporting adverse events should be created and clearly visible for users to access. GlaxoSmithKline, based in the UK and Pfizer, based in the US are good examples of how social media can be used once these policies are in place.
However these solutions have lead to the new biggest hurdle facing Pharma on Social Media. This new problem is not an externally enforced regulation but internally initiated reservations. To engage in social media as a Pharma company, you need to have transparent social media policies that ensure all social spaces are monitored. These policies not only take time to construct, but need employees to carry them out. On top of this, effective metrics for measuring return on investment for these efforts haven’t yet been established. So in essence, social media is a huge time and resource investment, with no measurable benefits. Without a quantifiable return on investment, companies are reluctant to make the rather large restructuring needed to implement a complete and efficient Social Media plan.
So why then, would a company even want to be established on Social Media? Apart from the more obvious reasons, such as to maintain and grow company awareness and sentiment, the answer is twofold. Patients and healthcare providers are talking about health-related issues on social media, and will continue to do so, whether Pharma is present or not. A company not engaged in social media is missing out on a wealth of real, rich data that can be utilised.
Recently the FDA released a guide for using social media, which many pharma folk have been waiting longingly for. And still, the colours haven’t been nailed to the mast. The FDA repeatedly mention that these are guidelines, not regulations, and that they are not legally binding. Here’s an FAQ outlining the key points of the published document.
European marketers have been looking for clarification for their market, and it’s worth mentioning that in October 2013 EFPIA backed the FDA’s standpoint and encouraged pharma companies to engage in social media.
So, bottom line is that the ground is still rocky. Policies, procedures and standard practices will change, which is why clarifying regulations is so difficult. Currently, the best practice for both US and European markets is to implement robust, flexible polices, and put time and resources into digital and social media. As it stands, Pharma companies aren’t comfortable doing this, but it is the cost of the patient centricity direction that the industry is moving towards.
This however should be seen as an opportunity for Pharma companies brave enough to embark in social media. Setting clearly defined yet flexible policies yields the best results in digital media. So while the leap to using social media is a large one, the companies that spend time defining goals and policies for social media usage will find that they have both short-term and long-term benefits.
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