Thursday, February 26, 2015

Is 2015 the year Pharma "Likes" Social?

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In 2014 the FDA finally began to carve out a position on social media. While the current guidance is far from complete, we are beginning to see definition around some of the key areas in social media where pharma would like to play. With a more definitive set of guidelines, expected to be released in the coming months (fingers crossed), the road forward for pharma in social media could become a little clearer.

This is an exciting prospect, but how ready is pharma for social, really? While some companies have been way ahead of the curve, many are just starting to think about social media as a viable channel. We’re getting there! But for those who are just beginning to test the waters, what should you be thinking about?


1. User-generated Content
Commenting, sharing, re-tweets…it can all seem a little overwhelming to manage. The good news is that the FDA will not hold brands accountable for social content that is deemed “truly independent”. This will likely free brands from direct responsibility for comments posted on or to their social channels, which allows for a more genuinely “social” interaction with users.

However, fear of negative brand comments and adverse event (AE) reports are often one of the biggest hurdles for pharma marketers to overcome as they prepare their organization to launch a social media channel or campaign. In fact, valid AE reports are extremely rare in social media—a recent study found only 0.3% of social posts contained an actionable AE. As for negative comments, the best thing a brand can do is be prepared to get ahead of a potential problem. Negative conversations will likely happen with or without you, so put processes in place to proactively address issues if/when they come up.

Takeaway: Think through every possible issue and develop a detailed response plan and protocol to prepare for user comments.

2. Fair Balance Requirements
Social media can be especially complicated for branded pharma communications because of fair balance requirements. Most social platforms are set up to deliver micro-communications that are structured around character limitations (eg, Twitter’s 140-character count). The FDA requires any brand message that includes both brand name and indication to carry the full fair balance. Posting the fair balance prominently on a brand’s social channel isn’t enough, especially when you consider that most social posts are viewed as part of a feed and not on the brand’s homepage.

Some pharma brands have gotten around this rule by creating branded social platforms that never mention the disease they are indicated to treat. While this can be somewhat effective if the brand name is well recognized, there isn’t much value for the user in Tweets or Facebook posts from a brand that can’t actually talk about what it does or the condition it treats.

Takeaway: As long as fair balance requirements remain as is, branded pharma communications in social media may not be worth the level of effort required to make them happen.

3. Internal Regulatory Preparedness
In many cases, ambitious or innovative ideas don’t make it through the medical/legal regulatory review phase. Due diligence is an important part of the process, so how do we manage regulatory concerns while also maintaining the essence of a social experience?

First, be realistic about what’s possible in a regulated environment. While it can often be creatively rewarding to push boundaries, it’s important to acknowledge that there are certain things we just won’t be able to say. Be mindful of where the roadblocks are and push your teams to think around them, not ignore them.

Second, in many cases, regulatory teams have little or no familiarity with the social media space. Sure, they’re probably using Facebook but they have likely never really thought about how social platforms work or what types of guardrails can be put in place to help pharma brands remain compliant with FDA regulations. Instead of throwing your hands up in the air and wailing about mean old regulatory, take some time to work with them to explain how each social media platform works and how you intend to manage it.

Takeaway: Make it your mission to help educate regulatory teams— it’s amazing what a difference this can make!

4. Planning and Resources
Once you’ve cleared the way to move forward with social media, how do you actually make it happen? An effective social media strategy includes meticulous editorial and engagement planning, as well as ongoing channel management. One of the biggest mistakes we see brands make is launching one or more social media channels without considering the need for a plan or a community manager. You’ll likely be able to spot these unmanaged channels in a couple of ways: 1) They post sporadically (some laying dormant for months or even years) 2) The channel content is almost entirely self promotional.

Don’t lose sight of the fact that it’s called social media for a reason. A brand should establish a unique voice and presence, interact with users (even if only occasionally), monitor the conversation and deliver compelling content that users are interested in. This takes time and effort. Don’t assume that you can get away with letting the channel run itself.

Takeaway: Community Management is a full-time job and it is well worth the investment.

Social Media is more than just a passing fad, it’s now firmly established as a valuable communications tool. With guidance becoming clearer for pharma, now is the time to explore what’s possible!

About the Author: Sarah Campbell is the SVP Group Director of Digital Activation at McCann HumanCare, an integrated health & wellness communications agency that’s part of McCann Worldgroup. Connect with us on LinkedIN.

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