In 2011, the FDA released its first social media guidelines. Since then, the world has seen new platforms emerge, social media fails, and a slew of feedback from the industry.
And that 9-year-old FDA draft guidance? It’s still just a draft.
For the life science industry, social media can be an overwhelming component of a marketing strategy. What’s required, and what’s suggested? Should you start using those new platforms? How can you ensure the content you’re sharing is compliant?
With the proper plan in place, social media can be a great way for your life science company to reach your marketing goals or build community. Here are 7 steps to an effective and compliant social media presence.
Step 1: Familiarize yourself with FDA resources
As always, the most obvious place to start is with the FDA. In addition to the 2011 document, the FDA has provided four draft guidance documents related to social media content:
- Fulfilling Regulatory Requirements for Postmarketing Submissions: of Interactive Promotional Media for Prescription Human and Animal Drugs and Biologics
Companies must submit websites they own and promotions they control on third-party sites (such as social media campaigns) to the FDA. The FDA recommends sending this content at the time of first display and, afterward, once per month.
- Internet/Social Media Platforms with Character Space Limitations: Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices
Even when promoting product benefits through a platform with character limits, such as Twitter, you should include risk information, a direct link to complete risk information, and the drug’s established name. If you cannot do so, reconsider using the platform.
- Internet/Social Media Platforms: Correcting Independent Third-Party Misinformation About Prescription Drugs and Medical Devices
Though you’re generally not responsible for third-party user-generated content created independently from your company, you can voluntarily provide corrective information through comments or, when not available, as a message sent to a content administrator.
- Responding to Unsolicited Requests: for Off-Label Information About Prescription Drugs and Medical Devices
People may ask questions about off-label use in public online forums. If you choose to respond, you should do so only for questions specifically about your product. Information about off-label use should not be posted on the public platform. Instead, you should provide the person who asked the question with contact information for your medical/scientific representative or medical affairs department. Answer their off-label question one-on-one.
In addition to familiarizing yourself with FDA guidelines, learn from other companies’ mistakes. Outside of the infamous Kim Kardashian case, there’s everything from the time Zarbees received a warning letter for liking claims posted by other users, to more run-of-the-mill examples like when Mannkind’s Facebook page for Afrezza did not include risk information.
Step 2: Set a goal
Your organization is drawn to using social media for a reason. What are you trying to accomplish?
Start by deciding on a focus. For example, you may be looking to improve brand awareness, like Allergan’s Allergan’s Facebook page for Restasis, or you may be interested in fostering a community, like Horizon’s Facebook community for thyroid eye disease.
Then, convert your focus into a measurable goal. If you’re trying to improve brand awareness, your goal could be guiding a certain number of visitors to your website each month. If you’re creating a community, your goal may be getting a certain number of new followers or likes per month.
Step 3: Create a strategy
Before you create an account on every social media platform, you’ll need to make a few decisions.
First, decide which platforms you’ll use. Make sure the platforms you select match up to your target audience. Consider other factors of the platforms, too, like Twitter’s character limits, which could be difficult for product-specific content, or the content investment required for YouTube videos.
Next, decide on the type of account and content. Should you create a corporate account that highlights company news related to brand values? Or would a product account be more appropriate? The answer should ladder up to your goal.
If you have multiple ideas, start with one, measure your success, then grow from there.
Step 4: Prepare for what could happen
Social media comes with its own array of unexpected user responses. Be prepared for common occurrences, like a negative comment or a popular but inaccurate post about your product.
Create the list of occurrences you’d like to be prepared for, then create a library of approved responses to pull from (see step 5). Provide guidance on how to use the responses, and leave some flexibility for moderators to adapt as needed.
Step 5: Set up a review process for social media posts
Because social media needs frequent updates and maintenance, you’ll want a review process that’s ready to handle your content cadence.
To start with, get regulatory buy-in on any campaign concepts. Don’t wait until you’ve written a year’s worth of social media posts only to be told that the concept isn’t compliant.
Then, decide on a process for approving posts. For example, prepare two months of posts in advance and have regulatory review in your promotional review system. Create a separate process for on-the-fly posts that need a quick turnaround time.
Step 6: Write a social-specific SOP
You’ll need a standard operating procedure (SOP) for your company’s social media presence to set compliant rules and processes.
Some of the things you should include in your SOP are:
- Social media platforms you’ll use
- Content strategy
- Who is responsible for posting and moderating
- How to moderate
Also, create a plan for keeping your SOP updated as the FDA revises its guidance. Keep track of upcoming plans, like the FDA’s potential plan to study the effect of influencers, and make changes as needed.
Step 7: Analyze your social media efforts
Remember that goal you created in step 2? It’s time to put it to use. At regular intervals (monthly, quarterly, etc.), check whether you’re hitting your goals.
Did you get the website visitors, likes, or followers you outlined in your goals? If yes, great! If not, dig into why and adjust accordingly. After all, why have a social media account if it’s not serving your marketing purposes?
Social media is a challenging, ever-changing landscape, particularly for the life science industry. But with a compliance plan in place and MLR software to help you review content, you’ll be well positioned to achieve your goals and maintain a compliant presence.