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Social media and pharma – What can you do?

What options are open to the pharmaceutical industry following the publication of PMCPA guidance on digital communications and social media?

A drug bottle with a 'like' option on the labelIn April the UK's Prescription Medicines Code of Practice Authority (PMCPA) published guidance on digital communications and social media. This is the first time the regulator has directly addressed this thorny issue. Alastair McQueen, senior copywriter at digital innovation agency eBee, examines what options are open to the pharmaceutical industry.

In an industry where every communication is (quite rightly) closely regulated, working with the dynamic, user-generated content that characterises the social media experience represents a unique challenge.

We've noticed a range of interpretations over what is permissible within social media under the Association of the British Pharmaceutical Industry's (ABPI) Code of Practice. Different individuals, departments and companies all hold different beliefs.

That's why the PMCPA's informal guidance on 'Digital Communications' – published on April 1 – is valuable. While grey areas are likely to persist until the relevant areas of the Code are put into practice in this context, the document seeks to bring some clarity to what the UK pharma industry can and can't do online and in social media.

Code of Practice
Elements of the pharmaceutical industry have been calling for guidance on social media for years. In the US, the Food and Drug Administration (FDA) has already confirmed that it is working on social media regulations, but it has not provided a timeframe. Originally due to be published within the first quarter of 2011, they have recently been delayed for a second time.

In the EU, where direct-to-consumer marketing of prescription medicines isn't permitted, the need for clear guidance on social media is arguably even more important. But while the European Commission has recently published proposals backing high quality pharma-produced health information for patients, they fail to tackle social media directly.

At least for the time being, the PMCPA publication is the only social media guidance available to the industry that has been produced by an established regulatory body. And though they only apply to companies operating in the UK, the guidelines are being closely scrutinised by the industry as a whole.

Critically, 'Digital Communications' highlights how companies are free to use any method of communicating to any audience – provided the audience is correctly identified and the relevant areas of the Code and pharmacovigilance requirements are adhered to.

A close read of the guidance reveals that the door for social media in pharma is wide open for those companies with the flexibility and vision to embrace it. Below we've listed some key activities open to pharma under the Code, along with some examples of what the industry has previously done in this area:

- Pharma can use social media to talk to HCPs. However, when targeting HCPs with promotional content, companies need to ensure that they have agreed to receive the information.

Specifically commenting on Twitter, the guidance states: 'Given these restrictions and the character limit on Twitter, it is highly unlikely that the use of this medium to promote prescription only medicines would meet the requirements of the Code.'

Although it isn't commonly recognised, you can restrict your audience on social media platforms. For example, YouTube and Twitter allow posters to restrict access to approved users only (in this case, validated HCPs). Alternatively, disclaimers to identify the intended audience (as already used on some HCP-facing websites), may be sufficient.

Nevertheless, it is worth noting that shortened links directly to prescribing information and high quality content could meet these needs in a well devised campaign.

- Pharma can use social media to talk to the public. So long as the material doesn't promote prescription medicines. Some of the most successful uses for social media have been patient facing disease awareness campaigns.

For example, the Janssen disease awareness campaign Psoriasis 360 makes use of YouTube, Twitter and Facebook.

 

Psoriasis 360 screenshot
Psoriasis 360 uses Twitter, Facebook and YouTube to reach psoriasis patients

 

- Pharma can use social media to talk to patients about the medicines they have been prescribed. So long as they've agreed to receive it and the information is non-promotional.

- Pharma can run forums or walls on established social media platforms or their own sites, but they must moderate. The most common concern we come across about using social media in pharma is over commenting. Discussions forums and comment walls, and the sense of community they foster, are integral to the social media experience – yet many companies are unsure how to approach them.

The guidance confirms that companies can run or generate these discussions, but that they are likely to be responsible for the content of these comments. This means moderating comments so that 'the only content to appear complies with the code.'

'Pre-moderation' – i.e. granting approval before the comment appears – is optional on YouTube and on certain blogging platforms. One successful social media campaign, Janssen's 'Living with ADHD' YouTube video, uses pre-moderated comments.

 


'Living with ADHD' has over 100 comments and more than 150,000 views

Facebook doesn't offer 'pre-moderation'. Consequently, disease awareness campaigns on Facebook often have comments closed on their walls (although the company itself is still able to post them). Other companies have chosen to allow comments on Facebook, but to closely monitor and remove any comments that breach the Code.

More recently, Facebook pages are being used to 'host' specially designed web content, which can include moderated comments. In such a system, user comments can be emailed, or input through a bespoke Facebook application on the page, before undergoing approval.

- Pharma can blog, or run blogging sites. But the blog content, whether written by patients or HCPs, would need to comply with the Code according to what audience it is facing.

Future promise
While the industry has been cautious about engaging audiences through social media, it's becoming increasingly clear how these activities can sit within the Code.

The greatest challenges lie in internal approval systems, which have seldom been designed with social media in mind. But by developing new approaches to managing two key issues: moderation, and guaranteeing that content reaches the target audience, we're already seeing real progress and results.

The Author
Alastair McQueen,
senior copywriter, eBee
eBee brings insight-driven innovation to healthcare communications. To learn more about engaging audiences through established or bespoke social media platforms, or for details on eBee's free 'Social Media and the ABPI' workshop, please email kate.reynolds@ebeehealth.com

28th April 2011

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