Tuesday, December 20, 2011

Social Media Posts that Keep Pharma Up at Night

2011 was the year social media came of age in the pharmaceutical industry. Bold statement? Probably. And certainly all the discussions, efforts, and thinking that took place this year are yet to be realized in the public domain. Social media policies are being drafted, platforms are being planned, and some new social efforts are being launched.

Yet also – some social media plans are still being stalled. Why? One of the largest hurdles for a regulated company to get over is addressing the perceived risk that opens up with a social media presence. The very nature of user-generated content and lack of control can be a scary thing indeed for pharma. Some threats are obvious, and others are not. But with proper preparation, many (though not all) situations can be planned for.

We often help our clients work through these issues ahead of a launch with their legal and regulatory teams. Just as in marketing, one of the best things we can do during this process is put ourselves in the minds of our audience and understand their concerns and pain points.

What types of posts keep regulatory folks up at night?
  • The Adverse Event Reporter: “Hi. I took this medication for the first time yesterday, and I developed a migraine. I’d never had a migraine before. Is this from the medication or something else? What should I do?”
  • The Complainer/Nay-sayer: “I had some nasty side effects with this medication – wouldn’t recommend it to my worst enemy.”
  • The Industry Ranter: “Big Pharma is Bad News – the entire industry reeks of fraud and profiteering over patient safety. Reform is needed!“
  • The Antagonizer: When perusing the Nicorette Facebook site one day, I noticed the comment to this post (check out the last comment) 

Charming.

Not necessarily what regulatory would be concerned about, but I can practically hear the ghosts of PR people past turning over in their graves. (And part of me wonders if the poster was John Mack just trying to stir up trouble anyway. Hmmm....)

So any of the above negative-toned posts could cause concern for a pharmaceutical company for various reasons.

And for not-so-obvious reasons, even positive comments can be a problem. May I introduce, for example:
  • The Miracle Worker: "This drug is so wonderful – it literally saved my son’s life. Thank you, thank you, thank you for developing this medication! It’s a MIRACLE!"
  • The Off-Labeler:"I know this is supposed to be prescribed for asthma but it really helped my allergies, too. Try it!"
  • The Cure Claimer: "My doctor said I’m cured. I’m so glad this medication is available."
Still? All of the above situations can be addressed within a moderated environment where all posts are reviewed and approved prior to going live. With the right processes and workflows in place, they can be handled swiftly, professionally, and with positive outcomes.

Consumers get a say, pharma stays safe, everyone goes home happy.

There is some healthy debate on the merits of a pre-moderation approach to social media. And I admit it is not a social-media-purist nor a perfect solution. But oftentimes in pharma, a little safety net is warranted. And moderation can be a “baby step” towards opening up discussion even further. 24/7 moderation is also a decent solution, providing the option to delete offending posts after-the-fact as long as they are caught. But that level of monitoring is not always necessary and can get expensive to manage.

So what's the right answer to dealing with the possible posts - bost positive and negative - that have pharma worryers saying "no" to social media still?  Working as a team, its up to the marketing, legal, regulatory, and agency partners to decide the threshold of risk and the right approach for them. 

4 comments:

PharmaGuy said...

Wendy,

Nice post. But I know for a fact that John Mack woud NEVER post such a disparaging comment on a pharma Facebook page! Even me, Pharmaguy, would not stoop so low!

Pharmaguy
www.pharmaguy.com

Wendy W. Blackburn said...

Hi, John:
Thank you for your comment and for the clarification. Of COURSE you would NEVER go onto pharma pages, sidewikies, or social media pages and post comments just to see what happened. Shame on me for even thinking you would do something like that.

Happy, healthy holidays to you John - stay out of trouble!
Wendy

Jason Boies said...

Hi Wendy,

Exactly how responsible are Pharma companies for comments made by others? Eg. Off label usage posts from members of the public.

Clearly, they'd be well within their rights to remove those posts. And it would help to both delete AND offer an explanation for the removal.

Is there a link to any articles discussing just how accountable pharma is for such posts? Forgive me if this is an easy answer.

This was a good read, by the way. :)

Jason Boies
Radian6 Community Team

Wendy W. Blackburn said...

Hi, Jason. Thanks for your comment and kind words-glad you found it helpful. Unfortunately there's no written rule or easy answer around how responsible pharma is for these types of posts. In my experience, the current interpretation by pharma co's is that if the comments are posted to a property owned or maintained ("controlled") by them, then it is their responsibility. If it's one that poses risk (per the examples above), they need to address it. This could include not publishing it, deleting it after the fact, or publishing it and then clarifying/correcting misinformation (and yes - definitely - if they delete or don't publish they should let the poster know why!)

The industry has been waiting on clarification from FDA on if this interpretation is correct, and also if pharma's responsibility spreads to additional websites outside of the company's control.

Each company has a slightly different interpretation and threshold for risk, but from what I've seen, this is currently the norm until things are clarified.