2009…nothing. 2010…nothing. 2011…doesn’t look like it.
According to the FDA’s “Guidance Agenda: New & Revised Draft Guidances CDER is Planning to Publish During Calendar Year”, ”Promotion of Prescription Drug Products Using Social Media Tools” was nowhere to be found. This was brought to pharma’s attention last week by John Mack, aka Pharmaguy. You can access John’s blog here; his blog also includes the link to the FDA’s Guidance Agenda.
But who needs to wait for the FDA. As per Marc Monseau & Shwen Gwee’s presentation at the May 24, 2011 MM&M Virtual Summit, the 3 key areas where pharma should currently be involved in social include:
- Identifying deep insights about the people who use our products and services and the markets we operate in
- Encouraging direct dialog between our company, products and brands and different stakeholder groups
- Creating relationships
Social can, and should, be done. Our patients expect it. You just have to be transparent, smart, establish policies, and most of all, remain flexible. Social’s not going anywhere…deal with it.
Pew Research does a great job with the big picture of social and health information. And their most recent report doesn’t disappoint.
The social life of health information is robust. The online conversation about health is being driven forward by two forces: 1) the availability of social tools and 2) the motivation, especially among people living with chronic conditions, to connect with each other.
Some of my favorite numbers:
- 6% of internet users have posted comments, questions or information about health or medical issues on a website of some kind, such as a health site or news site that allows comments and discussion.
- 5% of internet users have posted health-related comments, questions, or information in an online discussion, a listserv, or other online group forum.
- 4% of internet users have posted such comments, questions or information on a blog.
And if you remember there are close to 200 million internet users in the US alone, those are some pretty big numbers.
Great editorial from a recent Journal of Advertising Research.
The Shape of Marketing Research in 2021
By 2021, we think that leading-edge companies—probably led by consumer packaged goods and technologically driven enterprises—will look for answers to 80 percent of their marketing issues by “fishing the river” of information.
The river is an organic flow of knowledge. And how will innovative companies fish that river?
- Mobile Data
- User-Generated Content (UGC) and Text-Mining
- Social Networks
Get on board, or your going to miss the boat.

Social is not a brand Facebook page or a corporate tweet. It’s not a one-way push. Social is engaging and interacting with individuals at a personal level; that’s a two-way street. To date pharma has barely scratched the surface of one-way social, let alone done much of anything in terms of true, two-way communication.
Yeah…Yeah…Yeah…regulatory concerns. But if pharma uses common sense, a sound strategy, and sticks to their corporate mission, participating in two-way social is a win-win for everyone.
A recent article by Vernessa Pollard entitled FDA’s Social Media Enforcement: Emerging Rules of Engagement nicely lays out a handful of social guidelines pharma companies need to consider in the absence of specific guidance from FDA.
Should be required reading for all of Pharma.
Adam Kleger
With all the legal and regulatory issues surrounding pharma, how can the 21st century pharma company truly leverage the full power of social? It’s starts with listening and understanding.
In the research world, social is NOT just Facebook, Twitter, YouTube, etc. Social is over 200 million sites with user-generated content…it’s the world’s largest focus group. Real-time, unbiased, incentivized, unmoderated, patient and caregiver conversations…the holy grail of qualitative data!
In late 2010, the Marketing Research Association published MRA/IMRO Guide to the Top 16 Social Media Research Questions. Great introduction that reviews the role of social media research, ethical and legal issues, processes and providers, and much more. It should be required reading for the pharmaceutical market researcher (or brand manager) who is just dipping their toes in the social market research waters.

Don’t hold your breath waiting for formal rulings from FDA on how to deal with potential Adverse Events in social. But in the meantime, here are just a few of my favorite AE/social links: