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and offend a few more, but at the end of the day the FDA will never tell us exactly what to do; they will only provide draft guidance.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The emphasis of the draft guidance is on the appropriate treatment of off-label inquiries associated with prescription products.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!

By Rod Brooks, CMO of PEMCO and WOMMA President

Another Quarter In The Books

Wow! Where does the time go so quickly? It seems as though it was only last month that I was writing a recap of my first quarter as President of the WOMMA Board of Directors. Now it is the twelfth of July and we are already a week into Q3. It’s been a busy and productive time for WOMMA and I’ll try to bring you up to speed with a selection of key advances and accomplishments that have been made by our maturing association.

It’s been a real pleasure to lead and work with such a passionate group of volunteers that make up the WOMMA board. You’ll be pleased to know that the membership is well represented by an outstanding mix of global, national, and regional brands and agencies that truly have the best interest of WOMMA at heart. Add to that a staff that is led by Executive Director Kristen Smith, who in her third year at the helm has found ways to grow membership and revenue while delivering continuously improving educational events, partnerships, and programs. I’d like to offer the board, Kristen, and the entire WOMMA staff my sincere thanks and appreciation for another outstanding quarter of productivity and accomplishments. Let’s look at a few:

As great word of mouth practitioners know, it all starts with effectively listening.

School of WOM: After making a conscientious effort to examine the feedback from attendees of prior years and carefully reviewing submitted surveys, a President’s “Innovation Task Force” was assembled to explore opportunities to better differentiate our two major events – The School of WOM and The WOMMA Summit.

Several great ideas were brought forward, a few of which were implemented in Chicago at the School of WOM.

• Several sessions were converted to 90-minute workshops that allowed for both presenting valuable information as well as working through examples in a practical hands-on format.
• A speed-networking session was piloted at the end of the first day of presentations. Those who participated were able to seek out and spend valuable one-to-one time with specific companies and individuals that they were looking for suggestions and advice from.
• And speaking of networking, WOMMA was able to use POKEN technology to help make sharing contact information both easy and fun, while encouraging attendees to say hello in a friendly face-to-face way. The clever device was sponsored by Nology Media and was a big hit, generating over 3000 contact “pokes” by over 83 % of the 300 registered attendees.

WOM-COMM: With a full year of producing this program and listening to participant feedback under our belt, we have grown to understand that members who enrolled were more advanced than the 101 levels of content that we were providing. You asked for richer and deeper content, quizzes that were more aligned with the material being presented, case studies that were directly tied back to the course work, and less overlap within the first three modules. As a result, we reworked our lineup of presenters and coached them on the importance of differentiating the content between each module so that there is a building progression of learning. The quiz, which is mandatory, is written by WOMMA staff and is more aligned with the presenter’s key takeaways. The newly reformatted WOM- COMM online certificate program has just graduated its first class of students and we are eagerly awaiting their feedback.

President’s Innovation Task Force: A group of thought leaders from among our membership has been brought together on a quarterly basis to provide feedback and guidance to me as President as well as to our WOMMA staff. During Q2 a subgroup of the task force volunteered to develop a set of tools that would better enable current WOMMA members to act as advocates for the association. This work is currently underway and will be rolled out in the coming months.

Bringing our message to the market where they live and work.

Talkable Brand Exchanges: I’m very excited that we are now taking the WOMMA message and deliverables into regional outreach and educational events. The pilot program for these Talkable Brand Exchanges is intended to bring brands and agencies together who might not otherwise attend one of our national events. In addition to the February event, held in San Francisco, there are three events being planned for Chicago, Seattle and New York City. Check our member website for details on the event in your area.

Wine Wednesdays: WOMMA has schedule four Wine Wednesdays that will take place this summer in Atlanta, New York, Denver and Washington DC, with tentative dates for Chicago and San Diego. Wine Wednesdays are great opportunities for member companies to showcase their WOMMA pride by hosting a networking event in their city. To schedule your Wine Wednesday go here.

Adding value to our members and recognizing their accomplishments.

Customer Care Guidebook: Hot off the press in Q2! The Research & Measurement Council recently produced Best Practices Guide: WOM in the Customer Contact Centerfocused on understanding social media and customer service with six brands sharing their case studies. As a member only benefit, members can access the Guidebook in its entirety, by going here.

WOMMY Awards: The WOMMY’s are in their third year and continue to grow momentum and relevance in our industry. As the only awards focused on WOMM and Social Engagement we’ve gained credibility and international recognition. The WOMMY Chairs have added three new categories to the awards submission: Mobile, Cause Related Marketing, and Customer Relationship Management. These were added due to WOMMA’s recognition that these are growing areas of relevance and importance to our membership. It’s not too soon to plan your entry for this year’s WOMMY Awards.

That’s just a few examples of the work that your WOMMA board and staff have been doing on your behalf. It’s a great organization and one that is gaining momentum on a weekly basis. I urge you to talk WOMMA up in your organization and among industry colleagues. It’s in all of our best interest to include the thought leaders and practitioners that will help us grow the quality of our association.

I continue to be very excited about the opportunities that are developing in the online and offline space for word of mouth marketers. I hope you will join me by enthusiastically supporting and attending our upcoming events. As you know, your referral and recommendation is more highly regarded than anything WOMMA can say or do on our own behalf.

Have a wonderful summer.

Best regards,

Rod

Joe Chernov

By Joe Chernov, VP of Content Marketing, Eloqua

For the past month, various media outlets have been debating the merits of a social media campaign apparently run by the US military. The alleged program would allow individual US service personnel to use government-procured software to create and control multiple identities across various social channels. Translation: If reports are accurate, the US military will pay people to create fake personae (a.k.a., sock puppets) to, presumably, increase the volume of pro-American messaging throughout the social Web.

The concept of online transparency is one of the building blocks upon which WOMMA was built, so it’s understandable that observers like Jonathan Salem Baskin have begun to ask why WOMMA hasn’t taken action. The question is a fair one, and deserves a thorough answer.

We haven’t taken action for several reasons.

First, our “jurisdiction” – in terms enforcing our prominent Ethics Code – is limited to WOMMA members. It would be impossible for us to suspend or terminate the membership of an organization that never joined WOMMA in the first place. But more to the spirit of Baskin’s point, why aren’t we taking a public stand against the reported program?

Although we are tracking this news and discussing it internally, we haven’t been outspoken because our interests are aligned more closely with the Federal Trade Commission than with the National Security Administration. That is, we are focused, along with the FTC, on helping protect the interests of consumers against deceptive marketing practices. This objective is as important as it is ambitious, particularly given that the exponential growth of social channels had made it much more difficult to unearth and address unethical commercial marketing.

If the US military is engaged in practices that violate our Ethical Code, then we are disappointed that our plea for transparency hasn’t been heard as loudly in the public sector as it has in the private. We are also aware, however, that the guidelines that apply to businesses don’t necessarily apply to government, particularly when the objective is as vital as public safety.

The US military’s charter to protect American lives is elementally a different goal than ours, or the FTC’s for that matter. Do we think sock puppeting runs counter to the social Web’s ethos? Of course. Would we urge the US military to review our Ethics Code, attend our conferences, consult with our Member Ethics Advisory Panel, and even join WOMMA? Absolutely. We believe our experience and insights could help the military make informed, if not different, decisions regarding their social media efforts. But, at the same time, we also recognize the importance of protecting human lives is disproportionate to the importance of protecting consumer wallets. (Certainly one could debate the efficacy of creating fake profiles, but that’s a separate topic entirely.)

This contradiction brings us to the seminal question: Should the military be held to the same “social” standards as businesses?

It’s a provocative issue, and one we welcome discussing with the US military and its social media technology partners. We invite them to contact us, publicly or privately. WOMMA is, ultimately, in the education business. And conversation is an essential element of education.

Joe Chernov co-chairs the Word of Mouth Marketing Association’s Member Ethics Advisory Panel and serves as VP of Content Marketing for Eloqua, a revenue performance management company and proud WOMMA member.

By Jessica George, Director of Word of Mouth Marketing, Empower Media Marketing

Butterflies. Uncertainty. Anxiety. Panic.

We’re all familiar with the pre-date jitters. We remember what it was like getting ready to meet someone for the first time—that ridiculously awkward, dissonant feeling of hope (“not another dud who loves long walks in the park and his Chia Pet”) and fear (“please don’t let this one stalk me in Walgreens”).

These feelings are similar to those our clients express about engaging in social media. And, believe it or not, social media marketing and dating have more in common than just pre-date jitters.

The bad news? We have to overcome those jitters and get comfortable with a medium that puts us closer to our consumers than ever. The good news? If you’ve ever gone on a date, you know more about social media than you might think.

Let’s break it down by comparing common dating “dos and don’ts” to best practices for social media outreach.

Know where you stand

Before accepting that first date; we ask questions – and lots of them—to gauge potential. Who is he (audience)? Could he be a viable love interest (prospect)? How old is he? What does he do for a living? Where is he from? Who does he hang out with? What does he do for fun? Does he call his mom regularly? And so on.

The next questions are usually about you. What does he know and think about me? Why does he want to go out with me? Was this his idea? What does he expect from our first date?

Regardless of the specific questions, it all comes down to knowing what we’re getting into—and with whom—before engaging for the first time.

One of the beauties of the digital space is that we can use it to collect that information upfront in a fairly easy and cost-efficient manner compared to, say, focus groups. So rather than pulling our hair out trying to decide which of the barrage of social media tools to use, we first listen and learn from what consumers are saying about our brand, competition and respective category, then develop social media strategies from those insights.

Check your ego at the door

The reality is, consumers govern the digital universe and if we’re going to engage in personal, human dialogue; we need to take a personal and human approach.

Similar to a first date, if you talk only about yourself, don’t let the other person get a word in and – worse – act as if you don’t care about what he has to say – you can bet you’re going home alone.

It’s the same when engaging with consumers through social media. It is not just about you. We can no longer communicate with our consumers in a one-way monologue over which we have complete control. The heart of every successful social media strategy is building meaningful and lasting relationships with consumers. Instead of assuming that consumers live and die by our brands, we now have to understand what our brands mean – physically and emotionally – to our consumers and work to weave our brand into the fabric of their lives in meaningful and relevant ways.

The best traditional marketers have always understood this; social media makes it imperative.

Don’t play games

Don’t wait two days after a date to call. Don’t say you’re going to call if you’re not going to. Don’t lie about what you do for a living or how much you make. Don’t even lie about liking lobster, if you despise seafood.

The Word of Mouth Marketing Association (WOMMA) has a code of ethics centered on transparency. Never “flog” or participate in blogs and discussions forums under an alias. If this is happening, you need to stop it immediately, fire the agency that recommended it and report them to WOMMA.

Give your consumers the respect they deserve as fellow human beings by being candid and honest. That applies – even when you’re in the wrong. Honesty and transparency are how you build trusted relationships in the digital space.

Take it to the next level

As Dr. Phil says, “spice it up and keep the relationship interesting.” Reward consumers for their time and attention. Make your time together engaging and fun. Most important, respect that your brand image is dictated by the consumer and learn to value his or her point of view.

Respect breeds rapport, rapport breeds relationships and relationships breed loyalty. At the end of the day, building loyalty is what will put you ahead of the game.

Now what?

If you don’t know what consumers are saying about you in the social media space, find out. (My company and some others out there have tools to help you do this.

Similarly, if you don’t have a social media policy, think about creating one for your company. Not only are your consumers active in the space, but your employees, as consumers themselves, are as well. To leverage social media effectively, your entire company – from the receptionist to the board of directors – needs to know the “dos and don’ts” of being active in the space.

Jessica George is Empower’s director of word of mouth marketing and can be reached via e-mail at jessica.george@empowermm.com.

Image via Super Stock

One of the more important sessions at last week’s WOMM-U conference was on Ethics, Endorsements, and Your Next WOMM Program. Paul Rand, WOMMA’s Ethics Chair, and Anthony DiResta, former regional Federal Trade Commission (FTC) Director, discussed impending changes to FTC guidelines on testimonials in advertising.

Specifically, the FTC is seeking to ensure Advertisers and Bloggers are 100% transparent and always disclose when a blog post is being sponsored. “Sponsored Conversations” is the term being used to describe a situation where a business compensates a blogger in exchange for writing a post about a product/service a business provides. Lots of businesses are doing this and because it is a cost-effective marketing activity, it’s likely more businesses will be doing “Sponsored Conversations” with bloggers.

Additionally, the FTC is proposing to make Advertisers liable for the actions of their sponsored Bloggers and make the Bloggers personally liable for their actions.

Why? Well, the FTC is in the business of protecting consumers from unscrupulous business practices. The commission believes consumers must be protected from being influenced by bloggers who fail to be transparent and disclose they have been compensated by an advertiser. The worry, of course, is compensated bloggers may not give their honest opinion about the products/services they’ve been compensated to write about.

This issue gets muddier when it comes to defining compensation. Clearly, cash is compensation. But in-kind gifts and special access privileges are harder to define as compensation and payment. For example, is giving a blogger a book to review considered compensation? How about giving a blogger access to test drive a new car, is that compensation? Outside of cash, defining payment gets cloudy.

While there is much that is unclear with “Sponsored Conversations,” WOMMA has been very clear about its stance on Ethics and Endorsements as it relates to businesses and bloggers.

The WOMMA Ethics Code clearly asks businesses and bloggers to disclose their relationships and to disclose if the blogger received product samples or other incentives from a business.

The WOMMA Ethics Code also asks for honesty in all aspects of Word-of-Mouth marketing from truthfully disclosing relationships between a business and a blogger/customer and truthfully sharing authentic opinions with others about a product/service in online and offline conversations.

Designing and executing Word-of-Mouth marketing programs that follow the WOMMA Ethics Code of always disclosing relationships and always sharing authentic opinions is one way to avoid scrutiny and controversy.

Another way to avoid scrutiny and controversy when executing Word-of-Mouth marketing programs is to reconsider paying outright cash to entice bloggers and customers to either write something or say something about your business. (Just as in life, when money gets involved, issues seem to follow.)

Of course, the absolute least controversial method for businesses to get bloggers to blog and people to talk is to design products/services that are inherently worth talking about. (Yeah, yeah … easier said than done.)

It’ll be interesting to see where the FTC nets out on this important matter because lots of questions need to be answered. What ramifications are likely for Advertisers and Bloggers who run afoul of updated FTC guidelines? How will businesses and marketing agencies respond to the new guidelines as bloggers continue to gain more sway in helping to shape public opinion?

Let’s talk. The comments are open. The opinions will be varied. I’m sure you have something to share. Have at it.