Exactly one year ago, health care companies, online portals (from Google to health advocacy sites), and advertising agencies serving the health industry convened in Washington, DC, to voice their positions to the Food & Drug Administration (FDA) concerning pharmaceutical promotion and social media. It was such a monumental meeting that a tweetstream was initiated at the event that has been ongoing for the past year at #FDASM on Twitter.

Why would hundreds of individuals collectively spend thousands of hours airing their arguments, pro and con, on the issue of how pharmaceutical companies promote their products and services online?

“The drug industry allocated less than 4% of the more than $4 billion it spent on direct-to-consumer advertising to Internet otulets in 2008, and only a tiny fraction of that was for social networking sites. In the next year, however, the proportion may change substantially,” write Dr. Jeremy Greene and Dr. Aaron Kesselheim (who, in addition to being an MD holds a JD and an MPH) in Pharmaceutical Marketing and the New Social Media, published in the November 25, 2010, issue of The New England Journal of Medicine.

The authors point out three key aspects for doctors to watch when it comes to pharmaceutical promotion and social media:

  1. Lack of research on the health impact of communication about drugs. Clinicians will need to better understande the impact of social media on their patients’ health behaviors. For now, there are few insights that physicians would find credible.
  2. How are financial interests disclosed in new media? The topic of financial support for ghost-writing medical articles is front-and center in the media. Online, as the great New Yorker cartoon of the dog sitting in front of a computer monitor quips, “On the Internet, nobody knows you’re a dog.” In this case, there’s a lack of transparency among bloggers and other social media sites regarding what their financial relationship might be with a drug or device company.
  3. How can pharmaceutical companies maintain credible information in social media on risks and benefits of their products?  The authors recommend that doctors and consumers “hold the FDA responsible for maintaining” the risk/benefit information online in social networks. In particular, they assert that manufacturers are in a good position of monitoring online discussions about their products.

In conclusion, Drs. Greene and Kesselheim foresse that “regulators and manufacturers will have to share the responsibility for oversight” on social networks. 

Health Populi’s Hot Points:  This article is brilliantly timed, given the year that’s past since the FDA hearing. In June, the FDA publicly stated that they were “still on track” to issue guidelines for pharmaceutical companies and online promotion by late 2010. Since then, the FDA’s DDMAC division has presented in public and said that publishing the guidelines in late 2010 was “the goal.” However, such guidelines may not be available until 2011, and the BioJobBlog recently forecasted that FDA Guidance on the use of social media may not be complete until 2012.

In the meantime, health citizen-consumers don’t behave in a vacuum of arcane regulations; the market is the market. Most U.S. health citizens are already online searching for health information, and as many as 1 in 3 use social networks for health. In fact, health search has become so ubiquitous that the Pew Internet & American Life Project has taken a question on, “do you seek health information on the Internet” off of the survey instrument to make room for new data points.

While looking to engage with consumers online, one practical approach pharma companies would be wise to consider is the use of unbranded websites that educate people on conditions and provide useful tools for managing chronic disease. Manhattan Research has found considerable demand in their survey research for unbranded sites among consumers who already use the Internet to seek prescription drug information. While only 1 in 4 consumers seeking Rx information onlien trust manufactuer web sites, roughly 50% of U.S. consumers are open to using the web sites as part of their ‘overall research.’ It’s important for the FDA and manufacturers to realize that health consumers usually consult several web sites when seeking information about conditions.

Thus, while the FDA and pharma square off in the regulatory guidelines arena, health citizens are already ‘there,’ networking with each other and finding wisdom where they can. While Drs. Greene and Kesselheim look to the FDA and pharma manufacturers to “share the responsibility for oversight,” sooner would be much better than later.