Managing social media in the healthcare space can be challenging and must be approached with a unique strategy by brands. In my experience, a brand’s objectives for organic social media can run the gamut from listening and research, to marketing and engagement, to sales and CRM. (Not all at once, thankfully.) I’m focused on achieving success in the organic space, and leveraging insights to optimize a brand’s paid social spend. However, in my research on the health industry, it often seems that companies eschew interaction on social platforms, with their best case scenario avoiding any kind of pique or penalty. As such, too many paid social efforts appear unfitted based on the audience they are serving.
Somewhat inevitably, this approach leads to a disregard for several social media fundamentals – authenticity, balance, connectivity – a scheme not ideal for controlling the message. To be fair, it’s a not a universal failing, for I did come across some modestly successful provider-as-lifestyle-partner posts, and message boards with brand-as-facilitating-host. My first impulse was to diagnose a vicious cycle where lack of resources or talent led to a subsequent deficit in results, which in turn ensured a steadfast lack of commitment, and caused the under-investment in resources.
Learning the primary root of social media anxiety in pharma
I read industry blog after industry blog, which led me to the FDA’s Guidance for Industry documents. It is clear those drafts are daunting. During a recent poll conducted at an industry event, 95% of respondents cited compliance as the root of their reluctance to participate in social media. It was not a lack of resources, nor talent, and not a difficulty in measuring ROI.
Understanding the FDA and compliance
Knowing the reason why most companies are reluctant to add paid social as a channel, I decided to read every line and footnote in each draft guidance from May 2009 to June 2014. I read every warning letter or notice of violation stemming from digital media over the past six years. I studied the FD&C Act and the Electronic Code of Federal Regulations. I evaluated the advertising policies for each major social platform, even though I’m not a media buyer. I absorbed Mark Senak’s white paper, FDA Communications Oversight in a Digital Era, too. Finally, I called the FDA.
My own point of view is that exposure to warning letters, notices of violation, or adverse events occasioned by social marketing, is evidently overstated. By my calculation, since 2009, the Office of Prescription Drug Promotion at the FDA have issued only three WLs/NOVs specific to social media. As for the reporting of adverse events, I won’t make the mistake of downplaying their function. But I will say that of the sample studies I’m aware of, on average only 3% of posts include each of the four elements required for their reporting. That’s a low number, whichever way it’s spun. I did not discuss my views with the FDA, and the FDA was not able to answer all of my questions. However, I emerged from that conversation with clarity.
We talked about social media platforms with character space limitations (Facebook ads are character-limited). I also asked about reminder advertisements and reminder-like ads (which you should read more about, from the Food & Drug Law Institute’s Advertising & Promotion Conference, in October 2014).
What’s the risk?
The central tenet of my theory after the research, is that there is risk associated with any communication, but the notion that social media is some kind of unnavigable domain doesn’t stand up to scrutiny. The legal and regulatory culture is different at every organization and remaining in compliance is no easy task. Yet when a majority of violations are for omitting (or minimizing) risk, or because of unsubstantiated claims, one wonders how the content found its way out the door? It is possible that small firms will take more chances, but when bigger players are using self-denial as a form of discipline, neither strategy provides the means to achieve meaningful ROI from social.
The solution with social media has to be audience-first.
There are powerful listening and analytics tools that reveal a target audience: who the audience is, what the audience wants, when they want that, and how often to deliver it. This information forms the bones of a basic social strategy which is allied to an objective. Regardless of whether it’s Pharma/Rx, OTC, or HCP, the underlying objective is conversion. Successful conversion is best achieved by understanding the organic audience, which in turn improves paid-social creative, targeting, and performance.
For this to work at scale, I’d recommend becoming familiar with the June 2014 Guidance for Industry , the forthcoming use of links to third party sites, and understanding how a reminder or a reminder-like ad can be customized and tested, be creative but not careless.
In terms of the big picture conversation; if other industries are deploying custom contact strategies, why isn’t health? The most enduring social relationships originate from empowering exchange.
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