The Public Relations Strategist

Tweet Medicine: Clarifying How Communicators Can Use Social Media

October 16, 2014

[twitter]
[twitter]

As every PR professional knows, the value proposition of Twitter is the opportunity to disseminate small packets of timely information.

But when it comes to using Twitter to communicate information about prescription medicines, the Food and Drug Administration (FDA) seems to be saying, “Don’t bother.”

This is a shame, since according to health research consultants, IMS physicians spend twice as much time using online resources as they do print material, and nearly half of all consumers use smartphones to access health information.

Though it has not closed the door entirely on Twitter as a communications tool for prescription drug brands, the FDA has made it problematic, and its guidance has left some looming questions.

Five years ago, the FDA, sensing that social media was profoundly affecting how firms communicate with stakeholders, promised to issue guidelines on how medical-device and pharmaceutical companies could use online social platforms and networks such as blogs, Facebook and Twitter (then in its early days) to communicate with the public and health-care professionals.

True to its word, though a bit tardy, the FDA this year has started issuing draft Guidance for Industry position papers on various aspects of social media and other forms of promotion. This past June, it released its guidance on “Internet/Social Media Platforms with Character Space Limitations,” with the goal of providing recommendations on how pharmaceutical and medical-device companies could use Twitter, Google Sidelink and other limited-space social tools.

It’s important to mention that companies do not have to follow “guidance documents” from the FDA, but they are like “suggestions” from your boss — most companies pay attention.

Balancing the information

Thomas Abrams, director of the FDA Office of Prescription Drug Promotion, offered the following guidance in June:

We understand that communicating on electronic Internet sites with character-space limitations can be challenging. But no matter the Internet source used, benefit claims in product promotions should be balanced with risk information.

The bottom line is that the FDA does not see Twitter (for simplicity I will focus on that medium, though the FDA proffers recommendations for Sidelink and other media as well) much differently than they do other, more robust communications vehicles, such as traditional and Internet ads, and they essentially put forth the same guidelines with little consideration for the limits of 140 characters. Here are their recommendations:

• Information must be truthful and reveal material facts about the product. Each tweet must include the intended use of the product. All of this seems fair enough.

• If the firm is including benefit information for a drug or device, it must also include significant risk information within each tweet, and the prominence of the risks should be equal to that of the benefits. At minimum, companies must note the most significant risks associated with the product. This seems reasonable, but it makes each tweet a bit awkward.

• There must be a way to allow easy access to a complete discussion of risks linked to the product, such as including a hyperlink leading to a specific page listing the risks.

This starts to make things more difficult.

If the company concludes that the risk and benefit information is too complex and cannot be communicated effectively within the space limitations of Twitter, then the FDA suggests it is best to forgo Twitter as a means of communicating with the public. More journal ads anyone?

Tightening the phrasing

By now, you might be wondering if all of these requirements can be achieved within the puny universe of 140 characters? The FDA says they can: Suppose you have a product for mild to moderate memory loss called NoFocus. A tweet might read, NoFocus for mild to moderate memory loss (40 characters used, 100 more available).

While there aren’t any life-threatening risks associated with NoFocus, it can cause seizures in seizure disorder patients. So you have to add that in: NoFocus for mild to moderate memory loss; may cause seizure in patients with seizure disorders www.nofocus.com/risks (117/140 — still within the Twitter limit).

But the FDA also wants companies to include the generic name of the medicine, so there’s more text: NoFocus
(reemberine HCl) for mild to moderate memory loss; may cause seizure in patients with seizure
disorders www.nofocus.com/risks
(133/140 characters).

So, sure, you can cook up a tweet about the hypothetical NoFocus with characters to spare. But — and this is a big question — in the real world, how many prescription drugs have just one significant risk? The FDA says that the most serious risk needs to be on the tweet itself, and additional risk information needs to be included on a landing page linked to the tweet. But it might be a matter of opinion what the major risks are.

NoFocus (reemberine HCl) for mild to moderate memory loss; may cause seizure in patients with seizure disorders and weight gain www.nofocus.com/risks. One more risk means we are at 150 characters, and compressing the hyperlink is verboten. It won’t work.

Equally important — and by now pretty obvious — is that this hypothetical tweet won’t do the brand any good. While risk information has always been required in prescription drug marketing materials, devoting half of the communiqué to risk information — especially in such a small space — makes the tweet appear as a message advising against using the medicine.

Simply showcasing the medicine’s name (with the accompanying qualifiers) via Twitter is palpably useless in driving physician or consumer awareness.

In theory, there are three circumstances in which Twitter could be helpful in a prescription-drug PR program that are not addressed by the FDA:

1. Twitter could be an effective means of announcing the availability of a new medicine. A brand team could spend its prelaunch phase building a following through a nonbranded category (e.g., diabetes, depression) program, then use Twitter to let its community of followers know about the availability of its medicine at the time of FDA approval.

2. Twitter could be a great way to announce to health care professionals that the FDA has approved a new indication or use for a medicine.

3. Twitter could be a terrific way to announce new clinical-trial data on a medication. It’s not unreasonable even now for company representatives to tweet from medical conferences.

In each of these cases, Twitter could quickly inform interested parties about a medical development, if only by linking to a company news release on the matter. However, the FDA has said nothing in its guidelines about these real-life opportunities, and it is doubtful that pharmaceutical companies will use Twitter for these purposes without some clear signals from the FDA that it is OK.

Simplifying the rules

The FDA has not commented on the use of Twitter and other short-form social media for unbranded public education and disease-awareness programs. This information would be helpful. Would promotion of a company-sponsored awareness program on the signs and symptoms of major depression via Twitter be acceptable? Could a company promote its support of a program organized by a third party, such as World Diabetes Day, organized by the World Diabetes Federation?

The answer to these questions is “probably,” but these are the kinds of things that will keep the lawyers and regulatory-affairs experts up all night.

“I find it a real problem that the FDA doesn’t see Twitter any differently than traditional communications vehicles,” says Leigh Fazzina, a social media strategist and former president of the PRSA Health Academy. “I am hopeful, however, that once the FDA starts carefully listening to, monitoring and analyzing social communications through social media listening and analytics programs, it will become more understanding of what the social sphere is truly like.”

The FDA has taken an important step in trying to clarify how communicators can use social media. It is unfortunate that its guidance did not include more real-life examples that would provide clarity instead of simply introducing more questions.

The FDA is soliciting comments from interested parties on the pros and cons of this suggested policy. Due to the tremendous interest in the topic, the Agency has extended the comment period until Oct. 29. One can send comments directly to the FDA, or post comments here.

Michael M. Durand
Michael M. Durand is a veteran public relations and communications expert and former head of the Global Health Care Practice of Porter Novelli. Presently he consults with a range of health care clients and is an instructor at New York University.

Comments

Clarke L. Caywood, Ph.D. says:

It is 2016 (April) is this great commentary on a perceived poor fit of Twitter and other social media to medicine still viable? Has the FDA altered its recommendations? Thanks.

April 17, 2016

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