FDA social media guidance recommendations

I have been asked to recommend what guidance the FDA should provide to pharma companies for social media.  Here are my recommendations..

1ne: Allow pharma companies to Tweet their products without fair balance as long as fair balance is “one-click away”.  Let’s be honest, nobody is going to ask for a Tweeted product without doing some research first.  Why can’t a drug company say “Opdivo may give patients with advanced non small cell lung cancer a chance to live longer” with a link to their home page.

2wo: People reporting adverse events via social media would receive a reply with a link to “fill out an adverse event report”.  Drug companies should not have to fear adverse event reporting on social media because the people reporting them may not want to be contacted.  This, in fact, could be done using AI.

3hree: Drug companies who post on social media would have the responsibility to delete posts on their social media page that don’t support the product’s label, but since nobody can monitor social media 24/7 they would have a time-limit.

4our: Drug companies would use AI to answer any medical questions about their drug, but ultimately they would refer the patient back to their doctor or contact their doctor, with their permission,  and say “Mrs Smith, one of your patients, is interested in Victoza. You can contact Mrs Smith here”

5ive: Social media could also be used to provide insurance co-pays.  “Tweet us your insurer and we will let you know if Victoza is covered by your insurance and how much your co-pay might be”.

Finally, social media should be used to engage patients with industry thought leaders.  Why can’t a drug company sponsor a social media chat around depression and address key issues preventing people from getting treatment?  Why shouldn’t they talk about the benefits and possible side effects of their drugs in a way that is relevant to people?

If you see a Tweet for a new drug or an Instagram post of a happy woman who says that “she is fighting her depression with the help of Abilify” you’re not going to run to your doctor you’re going to go online first.   The FDA needs to recognize this and the fact that DTC does help patients seek treatment.

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