The Internet has become a primary source of information and education when it comes to research and decision-making in healthcare. The healthcare industry has been cautious about direct-to-consumer marketing because unlike the financial industry where there is FINRA to issue guidelines and regulate financial institutions digital media activities, the medical device industry and pharma only have “recommended” guidelines but nothing in stone from the Food and Drug Administration (FDA).
At the end of 2011 (December), the FDA issued draft guidelines on digital media when it came to off-label use of drugs and medical devices. Off-label meaning you can’t promote a device or drug for something that the FDA hadn’t approved it for yet. But as far as set guidelines there aren’t any, and none are expected any time soon. So what should you do?
1. Define target
First, medical device companies need to define who they want to reach with their product. If they want to reach the consumer, then their target may be on Facebook, Twitter, or Pinterest. However, if they want to reach a physician audience who is going to look for information on their device, then Facebook or Twitter may not be the answer. And let’s not forget YouTube. YouTube, the second largest search engine in the world, can be very effective in communicating the efficacy of a drug or device, but remember to include the risks or you might get a letter from the FDA. (See Atelvia YouTube FDA violation)
2. Set resources
Facebook and Twitter have a huge amount of traffic and require constant monitoring. So if you do engage on Facebook or Twitter then you may want to make sure you have someone whose full-time job it is to monitor your brand on those platforms since it is truly labor intensive.
3. Create a policy
Whether the FDA comes out with guidelines anytime soon or not, you still need a social media policy for your company. And understand that social media for medical devices (and pharma) go way beyond Facebook and Twitter.
4. Posts should include the good and the bad
When it comes to posting on social media sites, both pharma and medical devices need to understand that the FDA frowns upon companies who do not disclose both the efficacy and the possible side effects/risk information of a product. Additionally, the information needs to be one-click for the consumer. They can’t be expected to go three clicks deep to get to the risks of a product or drug.
5. Use of widgets
The FDA says that in order for promotional materials to be truthful and non-misleading, they must contain risk information in each part of a post or digital ad as necessary to qualify any claims made about the drug or device. (See Novartis 2o10 citing) In a 2009 statement from the FDA in response to social media concerns, they said:
“We believe it is a good idea for companies to have a robust policy in place for any type of promotion about their products, including social media promotion. We would advise them to carefully review their materials and processes to ensure that their promotion is compliant with the regulations. Consumers and healthcare professionals deserve an accurate and balanced picture of a drug product when it is promoted. [FDA’s advertising and promotion] rules apply regardless of the medium used. * * * all promotional communications about prescription drugs that are disseminated by or on behalf of a manufacturer [must] be truthful, non-misleading, and balanced.”
There are 99M Americans that use online tools to research and manage their healthcare. Whether you decide to use social media marketing or not for your medical device will depend on the factors above. However, since the FDA doesn’t have any real guidelines for medical devices yet, keep in mind that although they monitor social media platforms for violations, they may be looking for good examples of companies using social media as well and it’s where you can become a leader in your industry.