What I Like About the DHC Social Media Guidelines
In case you missed it, industry organization Digital Health Coalition (DHC) (on the Web here and onFacebook ) recently published self-imposedguidelines for how pharmaceutical companies should engage in social media (full disclosure: I am a "Digital Health Scholar" for the DHC, though I can’t take any credit for the guidelines).
The guidelines were released at the ePharma Summit conference in New York a few weeks ago.*
The DHC’s "Guiding Principles and Best Practices for Companies and Users" include the below 7 edicts, (paraphrased) with key points highlighted:
Regulated Healthcare Companies:
1. Should endeavor to participate in social media as a means to promote public health, improve patient outcomes and facilitate productive patient/physician relationships. 2. Are not responsible for user-generated content online that they do not control. Regulated healthcare companies are deemed to "control" health and medical content if (i) it owns such health and medical content and has material editorial authority or (ii) it paid for the creation of such content and has material editorial authority over such content. 3. Have a responsibility to report adverse events they become aware of. Regulated healthcare companies should follow the existing adverse event reporting rules in place at the FDA. 4. Employees should disclose their material company relationship when posting comments/content or engaging in an online conversation relating to a company product or relevant healthcare issue. 5. Should endeavor to respond to questions on sites they control within a reasonable period of time, and to implement reasonable measures to enable timely responses to crisis and emergency situations. 6. Should endeavor to make reasonable efforts to correct misinformation that is factually incorrect. 7. Should endeavor to appoint employee(s) tasked with the role of "patient liaison" focused on representing the best interests of the patient online.
What I like About the Guidelines:
- They are focused on public health, as FDA has repeatedly stated is its own mission.
- They are short, simple, and to the point. As a professional communicator, I am a fan of simplified communication. No need to write a book here.
- They’re common sense. No surprises. But somehow having them down all in once place makes these common-sense ideas more "real."
- It’s more than we have from FDA. In the absence of clear guidance from FDA (which may never come), the least the industry can do is offer up a consistent framework from which all can work.
- It’s a positive message to send from the industry as a whole. It says, "We’re trying. We care about doing it right." We have a responsibility to report AEs, to disclose, to correct misinformation.
The Challenges The Guidelines Will Face:
- Adoption by regulatory professionals who live and breathe by FDA code. Often, the regulatory reviewers’ job is to keep pharma companies from receiving FDA warning letters. That means referencing FDA guidance and precedence set by the agency. Less so, it means following self-imposed industry suggestions. While they’re a positive step that may influence future FDA guidance and pharma philosophy, they’re not law.
- The need for flexibility. As FDA slowly releases guidance this year (they released some nuggets in December and January but skipped February), we may need to re-evaluate any implications on the guidelines. Perhaps - even better - FDA is referencing these guidelines to draft their own guidance?
- The reality is these guidelines are a lot easier said than done. Behind pharma’s walls, companies are grappling with seemingly simple basics such as "responding in a timely manner."
- The reality of every pharma company appointing a "patient liaison" is far away. I personally love the idea. But maybe that’s why this one was listed last.
I support this effort and I admire that the group came together, created consensus, and got something "out there" so quickly. I’m curious if regulatory teams are posting this credo in their cubicles, and if companies are officially adopting them as their own. Or will it be just another blip in the ongoing noise around pharma’s engagement in social media? Let’s hope the former.
For an excellent point-of-view on other takeaways from the ePharma Summit conference, see my colleage @JimDayton’s blog post. He provides perspective on looking outside pharma’s walls for inspiration and innovation with themes such as mass personalization, big data, the quantified self, and the "Dragonfly Effect.") Adoption by the industry as a whole. The pharma industry - and especially the social media subset - is full of egos. Some may feel that, if they weren’t a part of this effort, they won’t support them.