The recent FDA’s Office of Prescription Drug Promotion (OPDP) draft guidance on Internet/Social Media Platforms with Character Space Limitations – Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices effectively bans Twitter for pharma advertising. It does the same with Google Sitelink ads.
K-messsage’s take on the FDA’s social media guidance from June 17th:
1. DO NOT use Twitter for promotional messaging about prescription drugs and medical devices
2. DO NOT use Google Sitelinks for promotional messaging about prescription drugs and medical devices
3. DO PERFORM social media monitoring to identify and engage in conversation about your prescription drugs and medical devices with misleading information on prescription drugs or medical devices
4. KEEP your Twitter presence for corporate and employer branding and for correcting misinformation
K-message believes that this is not what the Agency wanted to achieve, but we strongly suggest to all risk-averse pharmaceutical companies to cease any promotional activities for prescribed drugs in both space limited channels.
While the guidance includes imaginary examples of legally approved tweets and ads, in the real world it will not be possible to recreate such compliance for any of the existing products. Or at least it would cause a serious “Headhurtz” for the pharma marketing teams.
FDA requires to include in the tweet both benefit and risk information, and to link from the tweet to full page with Important Safety Information, preferably using word “risk” in an URL. As tweet has only 140 characters, it would be almost impossible to crunch in risks related to the product, even if you decide to skip benefit part.
The same happens with FDA’s proposal on how to use Google Sitelink ad format. The Agency may not know that, but what is displayed in the ad depends on the Google’s own algorithm, that tries to increase CTR. The chance of having very similar, risk focused links displayed under the ad, even if we manage to be always on the top of SERP, is limited. From our perspective the risk of not being able to follow the guidance is too high. Our recommendation is to use other Search Engine Marketing tactics instead.
Above does not mean, that pharma marketing on twitter is no longer possible. From the global perspective, the new regulation (if adopted without changes), affects only the United States market. Globally, there is no promotional activity directed to consumers, so there is no need to send promotional tweets. Instead, pharmaceutical firms focus on their corporate brands and disease awareness education – without promoting or even mentioning prescription drugs in the communication. So, yes, advertising prescription drugs and medical devices on twitter seems to be forbidden. But you should keep your presence there for
On the brighter side of the regulatory proposals, another draft guidance has been published. The Internet/Social Media Platforms: Correcting Independent Third-party Misinformation About Prescription Drugs and Medical Devices document paves the way to correct misleading or false information on pharmaceutical products and medical devices that is spreading over the web.
It will hopefully encourage pharma marketing departments worldwide to take a closer look into the social media and web monitoring in a search for online conversations around pharmaceutical brands and products. As the recent Accenture’s study shows, patients are expecting more of such engagement from the industry.