Can You Play Within the FDA Social Media Guidelines?

This article is part of ParkerWhite's weekly series, "Health and Wellness This Week," a roundup of the latest healthcare marketing news and what it means for your marketing strategy.This week, we are sharing information and insights about the July 17 release of draft FDA social media guidelines.

Long-Awaited Social Media Guidelines

The FDA social media guidelines were finally released after intense pressure from stakeholders and years of waiting. The guidance addresses correcting misinformation on websites run by others and promoting products where there are character limits, such as on Twitter and with Google search ads.In terms of communications with character limitations, the FDA would require companies to post benefits and main risks for a product, and are encouraged to use a hyperlink to risk information. Simple "reminder" promotions can include only the name of the product.Companies are not obligated to correct misinformation on third party sites, but if they do, their corrections must follow FDA guidelines, and they can't choose to "cherry pick," or only correct misinformation that portrays the product in a negative light.

An article on PMLive covers several of the FDA's recommendations, including:

  • Firms are responsible for product promotional communications on sites that are owned, controlled, created, influenced, or operated by, or on behalf of, the firm
  • Under certain circumstances, firms are responsible for promotion on third-party sites
  • A firm is responsible for the content generated by an employee or agent who is acting on behalf of the firm to promote the firm's product
"There's a public health interest in getting misinformation corrected, but if you're under no obligation to do so and you may stumble, why do it at all?" says Mark Senak, senior vice president and partner at FleishmanHillard public relations, who also writes the blog Eye on the FDA.

Marketing Strategy Insight

The draft of FDA social media guidelines signal a step forward for healthcare social media by at least providing some clarifications and rules for pharma and medical device companies. While some things won't change much, some aspects will become easier with established guidance.Keep in mind best practices for social media marketing when determining how this applies to your social media efforts. Generally, we don't advocate for companies to use social media as a medium for self-promotion. It's not an ideal way to make relationships or serve as a resource for valuable information. If brands focus on providing helpful, relevant information that's educational and more lifestyle-focused, they won't be talking directly about their product anyway.

Here is the example given by the FDA for a fictitious product:"NoFocus for mild to moderate memory loss; may cause seizures in patients with a seizure disorder"What does that sound like to you? Sounds like an ad. This isn't the type of content that resonates with consumers on social media anyway. However, if the company simply talked about memory loss in general, they're not asserting any claims about the product. For example,"Here's a helpful resource from the National Institute on Aging, "Understanding Memory Loss" #memoryloss"Under the guidelines content like this is acceptable. An added bonus: the U.S. government created the content shared in the link.

What You Can Do

This still allows brands to increase awareness, provide disease and condition information, and become associated with a particular topic. The majority of the time, especially for non-immediate purchases for products with a longer buying cycle, social media is not a direct sales channel. Think like a journalist, not a salesperson.

Build your brand first –when you have a strong brand, you don't need to use social media to hammer product features and benefits home (which rarely works anyway). People will come to you on their own, and when they're interested, they'll look up the information on your website or ask for more information from their doctor. This is the essence of inbound marketing.

Strong Brands To Lead the Way

Just look at how these two well-known brands approach social media:


Have you ever seen #Rio in the rain? @RedBullBR #justforkicks— Red Bull (@redbull) June 19, 2014

They could have said: "Red Bull makes you sharp, energized, and focused, so you can perform better physically and mentally. Like at the World Cup! But they don't need to make this kind of claim, because they've built a lifestyle brand around their product that speaks volumes for them instead. And they're essentially reminding you that Red Bull is about physical exertion and thrill – both of which are present at the World Cup.FitBit

Today’s challenge is: Find your motivation to run! What keeps you going? #30DaysToSummerFit— Fitbit (@fitbit) June 19, 2014

FitBit could have tweeted: ""FitBit will help you get more active so you can reduce the risk of dying from coronary heart disease and of developing high blood pressure.But guess what? That would be pretty boring and it doesn't do anything to engage fans. Right in the moment when people decide to exercise, they're not running because they want to reduce their risk of heart disease. It's about feeling good – and that's what FitBit is capturing here, reminding people about why they want to run. This is supported by the responses they received– people said they run because of their dog or to see beautiful trails. Those aren't clinical reasons.

Wrap Up

Overall, this is a good thing for healthcare marketers. We can expect to see more information coming from the FDA in the future. But just because the FDA is providing rules for social media use doesn't mean you can't still be effective within the boundaries. There's more than one way to skin a cat.

Can You Play Within the FDA Social Media Guidelines? - PW