By Andy Levitt, Founder and CEO of HealthTalker

Many people in the pharma world have been champing at the bit for the FDA to provide guidance on how to use social media in the promotion of prescription products.

For what it’s worth, I think that the use of social channels in the Rx space is widely over-hyped, and that the real opportunities lie in old fashioned, face-to-face word of mouth dialogue.  (Disclaimer: my company, HealthTalker, provides WOM services for life science companies).

Manufacturers and many of the agencies that support them have wondered how to avoid regulatory headaches but still tap into the power of Facebook, Twitter and the like, hoping to strike gold with these dynamic channels leading to noteworthy promotion and increased market share.

I actually find the whole thing a bit laughable as it suggests that people in the industry have become too afraid to think on their own, to apply good judgment to marketing and promotion, and to push the envelope a bit further.  That statement might anger some people and offend a few more, but at the end of the day the FDA will never tell us exactly what to do; they will only provide draft guidance.

The way the game works is that marketers will try to expand their reach; MLR teams will push back; and in the end, the most effective outcome will be finding the solid balance between appropriate promotion and persuasive marketing, no matter the medium.  But taking no action, standing on the sidelines and waiting for permission will never be the winning approach.

Have all of the social marketing secrets for pharma been revealed with the arrival of this new document?

No. When you take the time to review the guidance, there is actually very little here that will satisfy the curious and the hopeful.

Perhaps even more upsetting is that there is a perception that the FDA actually provided guidelines for social media in this document - when in fact, the entire emphasis of the document is about off-label use of products and how companies can adequately and safely respond.  Should the FDA earn kudos because they made note of Twitter as a “microblogging tool”?  That was nearly the extent of their reference to social media!

The emphasis of the draft guidance is on the appropriate treatment of off-label inquiries associated with prescription products. Though the subject matter seems very narrow in its focus, the document does provide several good examples, indicating when and how a manufacturer might communicate with interested consumers.

In the document, the FDA is saying it is ok for manufacturers to respond in a truthful and balanced fashion (one might have thought that even acknowledging an inquiry about off-label use might run afoul of what the FDA would permit).  However, that response needs to be done privately. In other words, the manufacturer firm cannot promote this information to the public at large.  Furthermore, sales and marketing personnel should have no input on the response, nor should the response be promotional in nature.

Really?  An off-label response shouldn’t be promotional?  The FDA needed to issue this document to tell us that?

Forgive my frustrations here, but what people in our industry really want to know about - and where this draft document fell short - is guidance about how to address on-label uses of a product.  Had this document included that sort of information, I suspect that it would open a floodgate of social and WOM activity where pharma would finally know where they can step, and where they can’t.

Right now, there is a paralysis that hinders pharma’s ability to engage with consumers in a natural and authentic manner.  It would have been great if companies were given a morsel of information about what they can do when someone makes a post about their medication’s effectiveness, inquires about a product’s known side effects, or even says that a certain drug has made a huge difference in their life. The FDA could even call it “Social Guidelines for Our Social World.”  How catchy.

Unfortunately, those guidelines won’t be coming anytime soon – if ever.   And this latest document doesn’t get us any closer.

Looks like we’ll just need to continue to rely on common sense!

Originally posted on Small Talk, a HealthTalker Blog

By: Andy Levitt, Founder & CEO, Healthtalker

As we head into 2011, brand teams and their agencies will be fine-tuning their marketing plans for the year. I doubt there will be dramatic changes in the general allocation of DTC budgets as most big brands will maintain a reliance on mass media reach and frequency patterns to raise brand awareness. And while print, PR, direct mail and digital will be in the mix, too, it’s safe to say that for the first time, “social media” will have a confirmed spot within most brand plans in the year ahead. It’s a big win, for sure - but the victory here may not prove so successful.

I’d hazard a guess that no fewer than 25 brands right now are trying to figure out how they can either develop or expand upon their Facebook pages. No doubt, plenty of MLR teams are struggling to find the proper balance, and the inherent limitations are most likely frustrating eager marketers.

Would the whole process be easier if it were called Health Media rather than Social Media? And isn’t that what brands want after all - people focused on health discussions, not on a host of other topics completely unrelated to growing their market share?

Last week, Reuters published an article that highlights the findings from recent research conducted by some smart folks at MIT. The big news was that groups of friends are key to changing health behaviors - but not in the way you would think. In fact, the headline screams out that “it takes more than a far-flung network of friends on Facebook egging you on; it takes a jostling herd.”

So maybe that Facebook page is less critical than you imagine.

In particular, the research discussed in the article (which is in the September 3 issue of Science) confirms that individual adoption of a particular behavior was much more likely when participants received social reinforcement from multiple neighbors in the social network.

What that means in English is that it’s the interpersonal connections - conversations with family, friends and colleagues - that really can influence behavior. It’s WOM 101, right?

The key is that the message needs to be consistent in order for the change and influence to occur. Therefore, when enough people in a network share a common viewpoint, it is likely to take hold and spread to most of the people who are listening. That’s where the big win takes place.

Don’t get me wrong - Facebook is an amazing platform, but I’d argue that its use is far more compelling for the social side of life, and less of a platform that can be leveraged to change health behaviors.

So perhaps the time has come for brands to think about creating the right platform for those influential conversations, rather than jumping in to the wrong place, just because now they can.

Andrew Levitt is the Founder & CEO of HealthTalker, a word of mouth agency that specializes in the healthcare industry