Pharmaceutical Social Media Marketing

Background

To date, the FDA has not yet published guidance for online or social media regarding pharmaceutical brand advertising and fair balance guidelines.

However, after 14 years of search engine advertising, the FDA’s Division of Drug Marketing, Advertising and Communications sent warning letters to 14 drug makers identifying 48 different brands as being in violation of the FDA’s fair balance guidelines. The letters stated that sponsored-link advertisements for specific drugs were misleading due to the exclusion of risk information associated with the use of the drug.

The FDA is holding public hearings starting today, Nov. 12, 2009 in Washington in the Federal Register, and comment letters will still be accepted through February 2010, after which it will take up to a year to publish draft guidelines, accept more comments from the public, and then publish final guidelines. 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.

Current Pharmaceutical DTC Using Social Media

Twitter Feeds (140 characters or less)

• Novo Nordisk’s Race with Insulin campaign follows indie racer Charlie Kimball’s experience with Levemir. Novo Nordisk trained Kimball to never write about the brand in the same tweet as the disease state. The Twitter page has prescribing information in the top left corner and any tweet that mentions the brand name has a link to the risk/benefit summary.
• Pfizer Twitter Feed posts publicly disseminated information, such as news releases, jobs openings, and speeches. At this point the company is not using Twitter for proactive product communications.
• Eli Lilly promoted its fourth biennial Lilly Oncology on Canvas art contest on a Twitter feed, announcing exhibition dates. The contest is running from September 2009 through to June 2010.

YouTube

• AstraZeneca launched a branded YouTube channel today for its asthma drug Symbicort, as well as a video blog, My Asthma Story (myasthmastory.com), a website calling for testimonial videos. Some risk information scrolls across the bottom margin of the videos while they play, and a link to full PI information appears near the top of the YouTube channel page.
• Santofi-Aventis’ YouTube channel, titled Go Insulin, offers testimonial video and links to GoInsulin.com, a companion site. Go Insulin is not branded.
• Abbott’s YouTube channel, AbbottChannel,
• GSK’s GSKvision channel has been the target of the Boston-based Prescription Project, who claim the videos for a new heart stent from Abbott’s Xience division do not properly disclose the known safety considerations that the company is required to disclose in other types of advertising. In response to the request to the FDA, Abbott originally said that a link on the brand’s AbbottChannel on YouTube that housed the videos was sufficient to provide “important safety information” on the product. But a few hours after the Prescription project made its request public, Abbott announced that it would embed such safety information directly into YouTube video spots for future promotions.
• J&J’s JNJ Health YouTube Channel posts unbranded health information. Video topics include ADHD diagnosis, ADHD treatment and living with ADHD.

Blog

• J&J’s BTW Blog discusses corporate and industry topics, but not product specific information.

Facebook
J&J unbranded ADHD sites:

• ADHD Allies targets adults features ADHD experts serving as online team leaders whom offer insight, experiences and advice to help other adults with ADHD take on its real-life challenges and realities.
• ADHD Moms targets parents of ADHD diagnosed children.