There have been two schools of thought on this question, and both, I think, have gotten it wrong so far.

Before I get to what I believe is a better way forward, some background: Facebook just surpassed 200 million members, and Twitter experienced 1,100% growth in just the last year alone –  so it’s become impossible for pharma companies to ignore the social media channel any longer.

But as companies begin to monitor social conversations, many have been flummoxed by the question of how to handle possible adverse events.

One well-publicized school of thought takes the following position:

“In most cases, social media monitoring will not result in reportable events as the
required identifiers will not be available in a verifiable manner. Postings on chat rooms or other social media outlets will typically not contain enough information to warrant an obligation or a prudent need to act further.”*

But this would be a very dangerous position for a responsible pharmaceutical company to take.  In the court of public opinion (and indeed, in a court of law) the defense that, “We knew about these things but weren’t technically required to report them,” will be, well, indefensible.

The other school of thought is what I call “the ostrich approach.” Some companies seem to be taking the position that,“If we ignore social media, maybe it will go away.” That won’t fly either, since the public (and regulators and perhaps Congress) will expect  a responsible company to pay attention to what patients, caregivers, and physicians may be saying about their products.

In my view, the best approach to AEs is a two-part process I call, conveniently, “AE”  for Awareness and Engagement. You shouldn’t forego the value of social monitoring – it can give you an unrivaled lens onto the perceptions, unmet needs and mindspace of your key customers. And you don’t want to ignore the bad stuff either. In fact, if a patient is publicly expressing a problem with your product, isn’t it worse if you are the only company unaware of it? So awareness is crucial.

And part two – engagement  – is equally essential.  If you see what may be an AE – even if the post is not ‘technically’  an AE – you should make a good faith attempt to contact the person, identify your role as a company representative, express your concern, and give that person a discreet way to discuss the matter in private with an appropriate company representative. Will the person agree to engage? Perhaps not, but you will have certainly made a good-faith effort to act responsibly, for the good of your patient, and your reputation.

*”Connecting with Patients, Overcoming Uncertainty,”  TNS media intelligence Cymfony, Envision Solutions LLC, Seyfarth Shaw LLP, September 2007