PM360 April 2011

PM360 FEATURE: BEST PRACTICES: The Highs and Lows of Social Media

By Neil Weisman

Despite many potential hazards, the promise of engaging patients through social media is great. It requires tremendous empathy and an understanding of the community environment as well as putting all of the ethical, legal, regulatory, and community protocols in place.

Social media is the most exciting and frightening communication vehicle for the healthcare industry today. On one hand, you have unprecedented access to highly engaged patients who are actively participating in discussions and seeking information and support for their disease. On the other hand, dialogue between community members is not controllable and attempts to intervene can have severe repercussions, both legally and publicly. Adding to the uncertainty is the FDA’s continued failure to issue clear guidelines on what is and is not permissible in the social media realm. In light of the potential hazards, the promise is great and healthcare companies are venturing into social media to interact with patients on a new level. It’s no longer about just pushing content; you’re opening up a dialogue directly with patients to discover what they really want to know.
Social media seems like a fairly simple marketing tactic to execute—post a message here, add a link there, develop a fan page. But it’s a complex and challenging new world. Utilizing social media effectively requires vast marketing and communication skills, and it mandates tremendous empathy and understanding of the community environment as well as all the ethical, legal, regulatory, and community guidelines in place.

EQUAL OPPORTUNITY TACTIC
Social media's allure extends not only to the marketing side of pharma, but to the R&D side of the house as well. Patient recruitment for clinical trials has long been a bottleneck in the clinical development process. With belts being tightened across the industry, clinical development teams are looking for innovative, cost-effective ways to communicate with potential study patients, particularly in small, hard-to-reach populations.

The missions of Marketing and R&D are distinct when it comes to patient outreach. Marketing wants to market their product. R&D has no approved product—it can't make any promises or offer a solution. It wants to motivate people to participate in a clinical trial. Beyond these differences, there is much overlap in how they accomplish their goals. Both want to educate and inform, provide an aspirational message, and motivate patients. They also share many of the same challenges when navigating the world of social media, particularly around ethical, legal, and community guidelines. In the absence of direction from the FDA, here are some best practices that we've developed to ensure that your social media campaign is “up to code.”

REGULATORY
One area in which post-approval marketing and clinical trials marketing are different is regulatory. A clinical trial is regulated by an independent governing body called an Institutional Review Board (IRB). All patient communications regarding a clinical trial must be approved by the IRB. If you want to post in a community forum, create a community page, develop a website, or send patient emails, all of these communications must be approved by the IRB. Communications cannot promise treatment, make any claims about the product, or be considered coercive or unethical.

If you're interacting with patients in an online community, all of your posts/replies must be scripted and IRB-approved ahead of time. This can be a challenge if you’re trying to appear as if you're engaging in a spontaneous conversation with community members. However, the more experience you have engaging with communities, the better able you are to anticipate the types of posts and replies that you need for your program.

As confining as clinical IRB regulations may seem, at least they're something to hang onto, compared to the void created by the lack of clear guidelines from the FDA. At their core, DDMAC guidelines on pharmaceutical advertising are similar to the spirit of IRB regulations: "To protect the public health by assuring prescription drug information is truthful, balanced, and accurately communicated."

LEGAL
The No. 1 rule when participating in social communities is to be transparent. There's been much talk about the new blogging laws, and these can apply to social media as well. You are not anonymous online. You must reveal who you are, the nature of your work, and your purpose for participating in the community. You cannot make any false or misleading claims about yourself, the product, or company that you represent. The content that you post must be your own, or you must give credit to the people you quote.

ETHICAL
There are gray areas for any law, and that’s where ethics come in. When participating in social communities, you want to know where the gray is and stay above it. Just because you can ask something of a patient doesn’t mean that you necessarily should. You want to exercise restraint, be respectful, and, above all, appear credible.

COMMUNITY
Social communities are interesting places. They can be both anonymous and intimate. People may share heart-wrenching stories about themselves or their loved ones, their treatment, their pain, their triumphs, and their hope for a cure. As a marketer, you are coming into these communities largely as an outsider. You need to tread lightly, with the utmost sensitivity and respect for the members. You need to find ways to gently interject yourself into their conversations in ways that are relevant and helpful. If a daughter is seeking treatment options for her elderly mother with Alzheimer's, you can offer support for the daughter's difficult situation and suggest a clinical trial that she may be interested in.

In our work with social media, the question often comes up as to whether marketers belong in these communities at all. For clinical trials, one of the biggest reasons that people do not participate is that they don't know about opportunities that may be appropriate for them. Posting clinical trial information in social communities gives patients this access, particularly when they are exploring treatment options. You are providing a valuable service of connecting patients with a potential healthcare option, one they may have had no other way to discover.

For post-approval marketers, the question may be one of intent. If your goal is to sell, persuade, or in any way preach, you will most likely be an unwelcome presence in the community. If your goal is to inform, educate, listen, and gain insights, then you may find yourself in the midst of an open and enlightening exchange of ideas.

CRISIS MANAGEMENT
But before we rush into social media, don't forget your emergency backup plan. Any good marketer knows that you must plan for the unexpected. The most frightening thing about social media is your lack of control over your
message once it's put out there. You must develop an action plan to manage/mitigate the possibility of negative conversation (about your product, about clinical trials, etc.,) misinformation, disclosure of inappropriate confidential information (i.e., about the specifics of your trial), and so forth. We recommend developing a list of Frequently Asked Questions ahead of time. It’s an opportunity to anticipate all the scenarios that might go wrong and establish your preferred responses. Have the write-ups reviewed by whatever regulatory or legal bodies you require, and then feel confident that you've anticipated the worst case to the best of your abilities. In crafting your responses, remember that you cannot change others' opinions, nor would this be well received in a social setting. You can only assert your point of view in a sensitive and respectful manner.

So much of pharmaceutical marketing up to this point has been a "push" of information, a one-way street to win the hearts and minds of the patients you serve. Social media is exciting because it allows communication to become a two-way dialogue, a "push-pull" dynamic to engage patients on a deeper and more meaningful level. In a sense, you are transcending your role from a “brand” to a “friend.” You’re no longer merely selling to consumers, you’re looking out for your friends.

Neil Weisman is Executive Vice President and General Manager of Blue Chip Healthcare Marketing, a division of Blue Chip Marketing Worldwide. Shortly after joining Blue Chip in 1999, he began developing proprietary models that accurately forecast response to patient and professional outreach. His analytical approach to marketing helps pharmaceutical and biotech companies bring new therapies to market faster and more efficiently. His healthcare experience is extensive, working with a wide range of clients including BioSante, Forest Laboratories, Johnson & Johnson, and Novartis. He can be reached at NWeisman@bluechipww.com