In that post (here), I said the FDA has been the butt of jokes on pundit blogs (e.g., here on Pharma Marketing Blog) and also behind "closed doors" at industry conferences. In particular, the agency was criticized for not being technically savvy enough to understand the nuances of social media and search engine advertising.
Two examples of FDA's lack of social media savvy are:
(1) the Agency did not understand how Google site links work and its example of an acceptable site link enabled AdWord could actually violate its own guidelines (see "Don't Follow FDA Guidance on Use of Google Adword Site Links"), and
(2) the Agency did not take into consideration mobile platforms in its guidance even though, as everyone else knows, mobile is probably the most popular way that consumers access Twitter, Facebook, and other social media "platforms."
A few of the comments to my LinkedIn post surprised me.
Jonathan Richman, Principal at Dose, healthcare marketing, said:
"I think the most disappointing thing here is that everyone seems to be mad that they can't send out tweets based on this guidance. Good grief. Is this really what pharma companies think is the most effective thing they can do to educate patients or doctors? If the FDA said you could put whatever you want in a tweet, would it make any difference? Would it help anyone understand your drug better? I'd rather pharma companies take advantage of the opportunity handed to them on a silver platter in the guidance around correcting misinformation and go out and fix some of the really bad advice that 'experts' post all over patient forums. This is something that would actually benefit patient care. It's not as sexy as a tweet, but it's actually the most beneficial thing that healthcare companies can do in social media today."Kurt Mueller, Chief Innovation Officer at PulseCx (formerly Roska Healthcare), agrees:
"Completely agree with Jonathan. There are opportunities we can leverage, but all of social media shouldn't be used for any/all reasons. Any strategy that doesn't seek to deliver an engaging customer experience that delivers value, will yield less than desirable results. We see this over and over. There are companies out there that get it, and are engaging physicians, patients, caregivers, payers, and other stakeholders all along the value chain. If what you're doing isn't a.) relevant; b.) engaging; and c.) delivering value -- don't be surprised if it doesn't work. And we need to get over the FDA not being up to speed. Google, Facebook, [insert next best thing company here] -- aren't going to wait or hold up their platforms for pharma. So get used to change and trying new things -- or think about getting out of the game."So here we have two savvy social media marketing consultants to the pharma industry saying that "die-hard" Rx brand pharma marketers need to forget about hawking brand name drugs via social media and focus on using social media to provide real benefits to patients.
I recommended this a long time ago before the 2009 public hearings at the FDA (see, for example, "Some Pharma Marketers Can't See the Unbranded SM Forest for the Branded SM Tree"). I'm surprised -- but happy -- to see this idea has traction with marketing experts who have a lot of experience working with pharmaceutical companies.
Sean Nicholson, JD, Digital Strategist, suggested that pharma may be as "clueless" as the FDA when it comes to social media:
"While I agree that the FDA doesn't have a clue as to what to do with social media, I would contend that the same holds true for many marketers in the pharma industry. Many are calling for 'clear guidance', but that's like asking the FDA to write a script that pharma marketers can follow when engaging at a cocktail party. Social media is about real-time, dynamic engagement and most pharma companies just aren't ready for that. Regardless of whether the FDA knows what they are doing or not."I especially like the comment about FDA writing a "script" for pharma marketers. The real pharma dunces, however, may be in the C-suite. For more on that read: "Pharma C-Suite Social Media Dummies: Can They Be Trained?"
Meanwhile, Casey Quinlan, Co-Founder at Patients for Clinical Research, suggested a solution to FDA's technical naiveté problem:
"FDA has no understanding of digital technology whatsoever. That's true from its cube farms to its leadership. I'll never forget sitting literally at Margaret Hamburg's feet last December at the mHealth Summit while she delivered a keynote address wherein she giggled about how tech-averse she was. I was glad I had my Macbook with me, so I could avoid throwing something at her and getting booted. I took to Twitter, knowing that there was zero risk that my heckling-via-keyboard would be noticed by anyone at FDA. This is why I keep telling the pharma industry to stop asking ever'body to 'ask their doctors about ... ' and to shift to 'let's break/fix this mess' - LET PATIENTS HELP. There's an army of Citizen Scientists ready to unleash."While some of these comments surprised me, the comment by Andrew Spong, MD, STweM Ltd., frightened me:
"There are many other factors at stake here - including the coming flight from DTC, and the end of what we currently call 'marketing' for pharma."I'm not happy to hear that we all will be out of business! Nah! Not in my lifetime.
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