Gov catches up with 2.0

The mass adoption of social media over the last five years has created both challenges and opportunities for communications and marketing professionals. Some of the challenges include working with a constantly evolving media industry and learning the new norms for communication – how we can and should connect with the public and share information. However, for every challenge that we face, we are presented with exciting opportunities to not only engage with the public, but also to gain insights, develop relationships and raise awareness of critical issues.

Members of the health care sector have been hesitant to engage with the public online, mainly because clear expectations or guidelines for this type of online conversation and promotion have yet to be put forth by governing bodies like the FDA, but some companies have ventured out on their own to connect with the public. GlaxoSmithKline and Johnson & Johnson are among a small but growing group of companies which have entered the social media arena via blogs and other channels, but few have boldly joined the conversation in the way that Novo Nordisk has with its Race with Insulin Twitter account.

Social Media in Action – @RaceWithInsulin

Novo Nordisk sent ripples through the social media, health and pharmaceutical communities this summer when they launched @RaceWithInsulin, a company branded Twitter account chronicling the daily activities of race car driver Charlie Kimball.

Charlie was diagnosed with Type 1 diabetes in 2007, and has partnered with Novo Nordisk to use @RaceWithInsulin to actively promote Levemir® FlexPen®, which the company is touting as the “world’s #1 selling prefilled insulin pen.”

How they’re breaking new ground:

• Choosing an Noteworthy Angle
  • The company selected a spokesperson with a high profile in a popular, exciting sport to demonstrate the active lifestyle of someone who, with the aid of their product, is living and thriving with this disease.
• Integrating Online Product Marketing with Awareness
  • The Levemir® team attempted to talk about the product within the frame of Charlie Kimball’s real-time, everyday activities. By doing this, the team managed to engage in promotion of the product, raise awareness of Type 1 diabetes and, via Kimball, reinforce the message that diabetes does not have to end your life or drastically slow you down.
• Being Bold Enough to Try
  • The team did their due diligence by developing an interesting strategy, albeit one with risk, largely because the FDA has not specifically addressed how social media should line up with other communication channels in terms of fair balance and adverse events reporting.

In addition to being an industry innovator by experimenting with social media, Novo Nordisk, via Charlie Kimball, has been able to start, and in some cases continue, a dialogue with several key stakeholders in the diabetes community, including organizations like the American Diabetes Association and people from respected blogs like Six Until Me, Diabetes Mine and others. Patients are already online talking about health conditions – cancer, diabetes, epilepsy, etc – and actively seeking out new options for improving their everyday lives. The value of campaigns like this comes from the relationships developed and the information gathered and shared in the process. 

Outstanding Social Media Questions

The Social Media landscape can at times seem like the “Wild West” because of how little guidance has been provided by federal governing bodies regarding what can and cannot be said. As a result, many key questions have been left answered.

• Can campaigns like Race with Insulin actually be done successfully? Will the FDA react with a warning letter similar to what was issued for Google AdWords?
• How will online audiences respond to social media campaigns focused on pharmaceutical products? How do you address adverse events?
• In the case of Levemir, the Novo Nordisk team provides a phone number people may use to report adverse events embedded into the background image of the Twitter page.
• All well-planned social media initiatives include detailed monitoring and measurement reports. Will such proactive monitoring make companies responsible for adverse events shared online in conversations that they did not initiate?
• How do you address fair balance in social media channels?
  • In the case of Levemir, a statement is embedded into the top left of the background image. This only meets Internet users halfway, however, as many access Twitter via mobile devices or online management systems which only display tweets.

The Time For Government Involvement

Washington is buzzing about both the potential for and application of social media within the government, and it has led the FDA to call a hearing for November 12^th – 13^th, 2009, to discuss the “Promotion of Food and Drug Administration-Regulated Medical Products Using the Internet and Social Media Tools.” Specific questions the FDA is addressing include:

1. For what online communications are manufacturers, packers, or distributors accountable?
2. How can manufacturers, packers, or distributors fulfill regulatory requirements (e.g., fair balance, disclosure of indication and risk information, postmarketing submission requirements) in their Internet and social media promotion, particularly when using tools that are associated with space limitations and tools that allow for real-time communications (e.g., micro-blogs, mobile technology)?
3. What parameters should apply to the posting of corrective information on Web sites controlled by third parties?
4. When is the use of links appropriate?
5. Questions specific to Internet adverse event reporting.

Though the government was primarily sitting on the sidelines when it came to social media regulation, there were several signs that government bodies were preparing to get involved in the dialogue on how online and social media channels should be used. The first was the round of warning letters issued by the FDA surrounding the use of Google AdWords, and the second was the set of guidelines put forth by the FTC regarding blogs, promotion and disclosure. The actions taken by the FTC have received a great deal of backlash, but clear guidelines and regulation should be looked at as an opportunity for members of the health care sector as it will provide boundaries within which real relationships can be developed, valuable information can be shared and lives can be saved. To make the most of this opportunity, companies should be active in the ongoing conversation, push to make sure the FDA addresses the many existing gray areas related to social media use, and be bold enough to experiment with the medium.

Resources:

• FDA Social Media Hearing Docket
• Live Webcast of FDA Social Media Hearing – November 12-13, 2009
• FDA Social Media Community Discussion
• Pharma and Healthcare Social Media Wiki – Examples of Social Media Use