I’ve always wanted to say this, so here it goes: “Do as I say, not as I do.”
Well, technically it’s not me saying it, but the FDA.
I’ve written quite a bit about the usage of social media in healthcare (here, here, and here) and there are a bunch of blogs out there dedicated specifically to this topic (check out my blogroll for a few). I’ve talked with hundreds of healthcare marketers over the years with one familiar refrain: “We can’t do social media. The FDA hasn’t told us what we can do or given us any guidance.” I wrote about this very fact in a post I half-jokingly titled, “FDA Isn’t Ready For Us…Stop All E-Marketing!” Half-joking. If you’ve seen a “2253″ form, you know I’m not totally joking. Haven’t seen one? Get your souvenir copy here. As I said in my post, of the 40 different categories of promotion recognized by the FDA, only one is Internet-based, the rather generic “WWW” category. That tells me that the FDA isn’t quite in the 21st century.
But I was wrong.
While I was searching around Twitter last week, I came across @FDARecalls. Turns out, for all their lack of regulations for social media, the FDA sure likes it. I couldn’t help but Tweet this: “FDA (@fdarecalls) uses Twitter, but doesn’t have any guidelines for using social media. I’ll take ‘Irony’ for $200, Alex.”
Much to my surprise, I got a response to my tweet from @AndrewPWilson, a “Member of the HHS Social Media Team” according to his profile. The WHAT?!? HHS (Health and Human Services, by the way), HHS Social Media team. They have a team dedicated to social media? They’re doing better than most healthcare companies. Of course, the FDA can’t really send itself a warning letter so they’re a little more relaxed.
Andrew responded with this:
@jonmrich Can you clarify what you mean by guidelines? Really like to know what you’d like to see. FYI – http://www.cdc.gov/socialmedia
We had a good exchange from there and I sensed that he genuinely wants to figure out a way to help healthcare marketers use social media in a compliant way. I’m staying positive for now.
I followed the link that Andrew included in his reply and found myself in government-sponsored social media nirvana. Follow along to “Social Media Tools for Consumers and Partners.” I couldn’t believe this page when I got to it. If I found it via Digg, I’d think it was fake. Here you’ll find everything related to social media that the HHS, FDA, and CDC does. Turns out that there are a lot of taxpayer dollars going towards interactive technology.What you’ll find on this page is a bunch of digital tactics that even the most digitally savvy healthcare companies have yet to try. The list:
- Blogs
- Email Subscriptions
- Health-e-Cards (Get it, health-e-cards…healthy cards…hilarious. The government even has a sense of humor when social media is involved.)
- Mobile (yes, they have a mobile site)
- Online video including a CDC YouTube Channel AND an FDA YouTube Channel
- Podcasts
- RSS Feeds
- Social Networks included a CDC MySpace page (yes, you can be friends with the Centers for Disease Control)
- Badges (yes, blog badges). You’ve got to see these.
- Twitter accounts including @FDARecalls, CDCEmergency, and CDC_ehealth
- Widgets. There are 10 total. Yes, 10. I recommend the Salmonella Outbreak Map
- “Virtual Worlds” Translation: Second Life. Yes, the CDC has an island in Second Life. Don’t believe me? You can’t make this stuff up.
I wrote this exclamation a while back in another post: “The question is: does FDA even know this is an issue? Who is the expert there on digital marketing who can help set the next generation of rules and regulations so that healthcare marketing can catch up to the rest of the world?” I also wondered aloud: ”If there is one person at FDA who knows how to use “The Computer” who reviews all of this stuff. If it’s got a “WWW” on the 2253, it just goes over to Ted in IT for a quick look.”
Ironically, it turns out the FDA knows more about digital than you. Yes, you. The average healthcare marketer. Do you know how and why you might use all these social media channels the FDA is using? In my experience, the answer is no. You said it yourselves actually. In a recent study done by MarketBridge, pharma marketers were asked to rate their understanding of digital marketing and nearly 45% said they “need to know more.”
So it turns out that the FDA is actually ready for you and your social media programs. They might even know more than you do. However, we’re still left without clear guidelines that would save everyone a lot of headaches. Until then, I’ll continue my quest to help get these crafted. If you’re interested in helping, please contact me.
Until then, I’ll just add this awesome badge on this blog.
I really enjoyed this and thank my friend for pointing it out to me. I have subscribed.
I really enjoyed this and thank my friend for pointing it out to me. I have subscribed.
FDA is having a public hearing on 11/12 and 11/13/09 to discuss promoting FDA-regulated medical products using the Internet and Social Media Tools.
SUMMARY: The Food and Drug Administration’s (FDA’s) Center for Drug Evaluation and Research (CDER), in collaboration with FDA’s Center for Biologics Evaluation and Research (CBER), Center for Veterinary Medicine (CVM), and Center for Devices and Radiological Health (CDRH), is announcing a public hearing to discuss issues related to the promotion of FDA-regulated medical products (including prescription drugs for humans and animals, prescription biologics, and medical devices) using the Internet and social media tools. FDA is seeking participation in the public hearing and written comments from all interested parties, including, but not limited to, consumers, patients, caregivers, health care professionals, patient groups, Internet vendors, advertising agencies, and the regulated industry.
This meeting and the written comments are intended to help guide FDA in making policy decisions on the promotion of human and animal prescription drugs and biologics and medical devices using the Internet and social media tools. FDA is seeking input on a number of specific questions but is interested in any other pertinent information participants in the hearing would like to share.
Dates and Times: The public hearing will be held on November 12 and 13, 2009, from 8 a.m. to 5 p.m. each day. Submit written or electronic registration by close of business on October 9, 2009. Written and electronic comments will be accepted until February 28, 2010.
Location: The public hearing will be held at the National Transportation Safety Board Conference Center, 429 L’Enfant Plaza, SW., Washington, DC 20594, 202-314-6305; Metro: L’Enfant Plaza station on the yellow, green, orange, and blue lines; see: http://ntsb.gov/events/newlocation.htm .
74 FR 48083 — Sep. 21, 2009 FDA source: http://www.CyberRegs.com
FDA is having a public hearing on 11/12 and 11/13/09 to discuss promoting FDA-regulated medical products using the Internet and Social Media Tools.
SUMMARY: The Food and Drug Administration’s (FDA’s) Center for Drug Evaluation and Research (CDER), in collaboration with FDA’s Center for Biologics Evaluation and Research (CBER), Center for Veterinary Medicine (CVM), and Center for Devices and Radiological Health (CDRH), is announcing a public hearing to discuss issues related to the promotion of FDA-regulated medical products (including prescription drugs for humans and animals, prescription biologics, and medical devices) using the Internet and social media tools. FDA is seeking participation in the public hearing and written comments from all interested parties, including, but not limited to, consumers, patients, caregivers, health care professionals, patient groups, Internet vendors, advertising agencies, and the regulated industry.
This meeting and the written comments are intended to help guide FDA in making policy decisions on the promotion of human and animal prescription drugs and biologics and medical devices using the Internet and social media tools. FDA is seeking input on a number of specific questions but is interested in any other pertinent information participants in the hearing would like to share.
Dates and Times: The public hearing will be held on November 12 and 13, 2009, from 8 a.m. to 5 p.m. each day. Submit written or electronic registration by close of business on October 9, 2009. Written and electronic comments will be accepted until February 28, 2010.
Location: The public hearing will be held at the National Transportation Safety Board Conference Center, 429 L’Enfant Plaza, SW., Washington, DC 20594, 202-314-6305; Metro: L’Enfant Plaza station on the yellow, green, orange, and blue lines; see: http://ntsb.gov/events/newlocation.htm .
74 FR 48083 — Sep. 21, 2009 FDA source: http://www.CyberRegs.com