“If everything seems under control, you're not going fast enough.”
As social media participation by regulated healthcare companies continues its slow slog forward, here are some issues to ponder:
Intent. Internal company debates often focus on responsibility for what happens after a corporate comment is posted – and that's important. What's more important is what drove the company's decision to make the post in the first place. What was the intent? Was it marketing-driven? Or was it done in the best interest of a patient or the broader public health? Intent counts. Just as the FDA has asked whether or not the speaker and the audience matter when it comes to the issue of “scientific exchange,” so too is this relevant in helping to determine “responsibility” for what takes place on a social media site post a company's post.
Does this mean that, at least initially, regulated healthcare speech in social media will be more corporate versus product driven?
Control. When it comes to the “property owner vs. property user” question – what is the difference between “sponsorship,” generally defined by an exchange of money, and “control,” a more ambiguous but no less important concept? If you control something, then can you be considered able to prevent something from happening – such as a discussion of off-label use?
Environment. Digital advertising and social media are not the same thing. If you buy a banner ad on Google, that's advertising. But if that ad appears above an organic search that you do not either sponsor or control, are you responsible for the broader environment of that page? Perhaps the best way to approach that question is to offer this thought experiment: If you decided to run a commercial for a statin on the evening news and, during the course of the program, there was a feature on off-label use of statins – would you be responsible for the environment?
Safety information. Is it a good thing or a bad thing for consumers to spend more time interacting with important safety information? Of course it's a good thing. So here's a question that's calling for some solid research: do consumers spend more time with ISI via the traditional off-line “brief summary” and patient package insert, or on-line via click-throughs? Inquiring minds want to know. If it is the latter, then that would further strengthen the argument that it's important for regulated healthcare companies, on both corporate and product fronts, to participate in social media for the public good.
Commitment. Perhaps the one thing that is the toughest to internalize is that social media is a commitment – not a tactic. Obvious financial and FTE implications here but, more frustrating, is the fact that participating in social media means playing with irrational actors – like patients.
So much for “control.”Peter J. Pitts is president of the Center for Medicine in the Public Interest, a former FDA associate commissioner, and a member of the Digital Health Coalition's board of advisors.