At a recent FDA/CDER-CHPA seminar on
promoting over the counter medicines in a social media world, experts wrestled with the fact that consumers are increasingly turning to others like themselves or other online channels for health information, data, and first-hand experiences to help them make better medical decisions. Almost half of consumers are reading someone else’s commentary or experience about health or medical issues on an online news group, website, or blog. They are turning to social channels and platforms because they want customer service, immediate answers to basic questions, guidance and someone to make sense out of the cacophony of medical information.
The challenge this poses for healthcare companies is how best to get involved in monitoring and correcting misconceptions or misinformation. There is great upside and promise of social health promotion and marketing including sharing experiences, driving better behaviors and spreading useful information. However, there are cautions to take into consideration when using social media to promote healthcare products and medicines including the risk of misinformation spreading and information being taken out of context.
Rules against misleading advertising also apply to social media. The FDA, FTC and leading legal experts on social media marketing all cautioned that the prohibition against deceptive and misleading advertising applies to social media marketing. Advertisers can’t make claims using third parties that they couldn’t legally make themselves. Consumers have the right to know when they are being advertised to.
Celebrity endorsements via social media must be disclosed. When it comes to using celebrities to endorse products, in conventional ads, it’s not necessary for an ad to disclose that a celebrity is being paid, because in that context payment would be understood. Outside of conventional ads however, for instance on talk shows and social networking sites, the relationship with the advertiser should be disclosed when a celebrity talks up a product because payment isn’t obvious in that context. In addition, companies using bloggers or consumer endorsers as part of their campaigns must have policies in place to monitor whether disclosures are being made.
Best practices for monitoring and reporting remain a priority. Social media is a new data source for both industry and regulators. It is more far reaching and in a less controlled environment than traditional sources such as phone, email and postal letter. There is increased case volume to monitor. Companies need to be vigilant when following up with a post on a company site, while being mindful of privacy concerns. Company privacy policies should also be consistent with adverse event reporting activities.
These questions are not necessarily easy to answer but will remain important to ask as social media for healthcare promotion becomes more and more expected and accepted.
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