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Digital Expert Q&A

  •   What are the main takeaways you had from the FDA hearings on social media a couple of weeks ago?

    Answered January 4th, 2010 by Expert: Bill Drummy

    I recently wrote a detailed wrap-up of the hearings (link to article at the end of this post) and in thinking back on my experience I perceived three broad themes:

    1. The need for “radical simplification”
    2. The potential of technology to improve the dialogue
    3. The limits of pharma responsibility

    The need for “radical simplification”

    The current behavior for pharma when it comes to online advertising is to stuff as much disclaimer and Important Safety Information (ISI) into an ad to ensure the pharma company is “covered.” Think about it – have you ever read the entire privacy policy of a website or the terms and conditions for your credit card? Likely not. The same goes for ISI. How is it really helping patients?

    Instead of just saying simplification is needed, Google presented a potential solution for search and I offered an idea for how to handle display ads. Our ideas were developed independently, but ended up in a remarkably similar place: reduce information to the most important details for consumers and then allow them to click-thru for the full information. (You can see the actual examples in my wrap-up article below.)

    Quite simply, less is more.

    The potential of technology to improve the dialogue

    In general, pharma tends to handle the digital environment by transferring offline techniques to the online space without thinking about the unique characteristics and potential of the internet (think e-detailing, Websites that look like prints ads, and the mountain of ISI data we’ve been discussing). Some of this is due to a lack of innovation, but a good deal of it is to ensure they are complying with FDA requirements – even though none exist for the Internet (hence the hearings). Guessing leads to clunky solutions.

    Yahoo presented some innovative ideas for tackling the safety issue, taking these unique characteristics into account. They suggested pop-up windows that include ISI and video solutions playable directly from search ads, giving users unlimited time to see as much information as they want which can only improve consumer comprehension.

    The limits of pharma responsibility

    No topic was hotter than the freedom and responsibility of the pharma industry to participate in social media conversations about its products. Several speakers presented original research prepared for the hearings to gauge consumer and HCP interest in pharma’s participation and a strong majority showed they would welcome pharma’s involvement. Of course, not everyone agreed, with one speaker suggesting pharma should even be held responsible for monitoring Wikipedia (yowza).

    There was also a lot of talk regarding adverse event (AE) reporting – one of the top concerns for pharma. One speaker noted a small percentage of social media comments would actually qualify as AEs and others noted that pharma cannot possibly handle monitoring all these conversations from a resource perspective.

    In my opinion, both these arguments are shortsighted. First off, software tools can scan the Web and uncover significant mention of a product and those comments can be categorized and reviewed (we do this regularly for clients).

    But even more importantly, why put such a restriction on what a “qualified” AE means? It would seem critical to pharma’s business to know exactly the issues being reported so they can investigate, assess and correct. This could likely improve patient outcomes AND the opinion of pharma in the court of public opinion.

    Find my full wrap-up of the hearings here.

    In addition, you can access a video of my two presentations at the hearings here (PC format only) .

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