Overcoming Pharma's Social Media & Mobile Challenges
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© 2013 Pharmaguy
Overcoming Pharma’s Social Media & Mobile Challenges
Presented 11 June 2013 at:
Bayer PharmaBerlin, Germany
© 2013 Pharmaguy
Learn from Milestones & Mistakes
Milestones – Important “firsts” have
paved the way for cautious followers.
Mistakes – Best way to learn & benefit
from your competition’s errors.
“Constant Effort and Frequent Mistakes are the Stepping Stones to Genius”
Elbert Hubbard, American writer
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© 2013 Pharmaguy3
Pharmaguy Has Been There (at FDA), Done This
Testified as Panel Member at 1996 FDA Hearing on Internet
Co-Founded Internet Healthcare Coalition (1997)
Co-Authored the eHealth Code of Ethics (2000)
Blogged About Pharmaceutical Digital Marketing Practices Since 2005
Presented Survey Results at the 2009 FDA Hearing on Social Media
© 2013 Pharmaguy
FDA Sends 14 Warning Letters
FDA sends 14 letters on a single day to major pharmaceutical companies concerning their Google and Yahoo Rx paid search ads. Letters were dated 29 March 2009, but made public on 2 April 2009.
April 2, 2009
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1 April 2009: Pharmaguy posted fake “April Fools” press release announcing publication of FDA guidance on pharma’s use of social media.
© 2013 Pharmaguy5
FDA Hosts Public Hearing
November 12-13, 2009
“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.”
April 2, 2009: Pharmaguy issued first public call for FDA public hearing on social media. “We should make sure that when it comes time for the FDA to actually create a guidance document on social media that it does it with input from ALL stakeholders.”
© 2013 Pharmaguy6
Survey Results Submitted to FDA
Accountability, Disclosure, Corrections
Fulfilling Regulatory Requirements with Regard to Fair Balance and Submission for Review
Posting Corrective Information
Adverse Event Reporting
354 Responses575 Comments
http://bit.ly/fdasmSurvey
© 2013 Pharmaguy
Accountability
For what online communications are manufacturers, packers, or distributors accountable? In particular, when should third-party discussions be treated as being performed by, or on behalf of, the companies that market the product, as opposed to being performed independent of the influence of the companies marketing the products?
When marketer or agent sponsors the discussion (e.g., provides a specific grant to independent 3rd-party host such as a patient advocacy group to sponsor the discussion)
When marketer or agent paid for the content (e.g., paid patients for testimonials or otherwise provided compensation)
When marketer or agent paid for display ads to be run on specific discussion pages (e.g., only discussions related to the product advertised)
3rd-Party Independence
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© 2013 Pharmaguy
Accountability: Best Practices
DISCLOSURE of involvement with or influence over 3rd-party social media content should be prominently displayed alongside relevant content when possible. Half of survey respondents agree
Each company should have a Public Social Media Policy (SMP) that includes a notice of its transparency/disclosure and other policies relating to social media. [Just like every pharma company has a public privacy policy that applies to all its product Web sites, each pharma company should have a public SMP that applies to all its social media activities, whether owned or sponsored by the company.]About two-thirds of survey respondents agree
Companies should monitor social media sites for unauthorized use or modification of its approved content and make a best effort to remove or correct the content. But they should only be REQUIRED to do so only for sites owned or directly sponsored by them.
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© 2013 Pharmaguy
Parameters for Correcting Misinformation
Are there any parameters or criteria that could be used to determine the appropriateness of correcting misinformation and/or scope of information a company can provide when trying to correct misinformation on a Web site outside a company's control?
ONLY misinformation of real and imminent danger to the public health (to be determined by company) should be corrected
ALL off-label claims—even if supported by peer-reviewed medical literature—should be corrected)
Only off-label claims NOT substantiated by peer-reviewed medical literature should be corrected
Companies should not be burdened by FDA regulations requiring them to make corrections about ANY product misinformation published on 3rd-party sites
Posting Corrective Information
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© 2013 Pharmaguy
Should Pharma Edit Drug Articles on Wikipedia?
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© 2013 Pharmaguy11
What challenges are presented in handling adverse event information from these sources?
The amount of information from these sources is potentially too vast to be processed economically (lack of resources)
Finding adverse event information from these sources is like finding a needle in a haystack (too daunting)
The information is usually incomplete and does not meet the requirements for submitting a meaningful AER (not actionable)
There are many potential issues that won't fully be known until the practice of monitoring social media for AEs is more prevalent (unknown issues)
Adverse Event Reporting
Social Media Adverse Event Challenges
© 2013 Pharmaguy
“UCB has an ethical and legal responsibility to report adverse events associated with our drugs. If adverse events for any UCB drugs are mentioned on the site, UCB is required to report these directly to the U.S. Food and Drug Administration (FDA). Therefore, we are working to develop and deploy a solution that will allow us to assess and process potential adverse events, report them to the FDA, and capture them in the UCB safety database.” -- Peter Verdru, MD, UCB’s Vice President of Clinical Research
Goal: Generate patient-reported outcomes that may help
UCB better understand how patients live with epilepsy
and help advance epilepsy care.
Provides disease tracking tools
Deployed a system for reporting adverse events to FDA
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UCB Embraces Adverse Events on Sponsored PatientsLikeMe Epilepsy Discussion BoardJune 16, 2009
© 2013 Pharmaguy13
13 June 2011: ABPI Pharmacovigilance Expert Network (PEN)
published “Guidance Notes” on management of AEs on pharma
owned/sponsored Websites; AEs should be collected and
documented, regardless of seriousness of event and whether or not
there is an identifiable reporter (http://bit.ly/BritAEguide)
1 April 2011: PMCPA issued “informal guidance” for applying its
Code to social media; e.g., communication with physicians via
Twitter, corrections to Wikipedia, appropriate use of metadata (
http://bit.ly/PMBBritsvFDA)
EU Online AE Reporting & Twitter Guidance
© 2013 Pharmaguy14
"Miscellaneous Provision" of the "Food and
Drug Administration Safety and Innovation Act"
(aka PDUFA)
“Not later than 2 years after the date of
enactment of this Act, the Secretary of Health
and Human Services shall issue guidance that
describes Food and Drug Administration policy
regarding the promotion, using the Internet
(including social media), of medical products
that are regulated by such Administration.”
FDA's "Social Media Guidance Cliff"
New Deadline is July 2014
As of 30 May 2013, no “actions completed” reported in FDASIA-TRACK
© 2013 Pharmaguy15
December 27, 2011
Section VI addresses responding to unsolicited
requests on public forums such as the Internet
and "emerging electronic media”
Cites cases on YouTube, blogs, and Twitter:
Pharma should respond to unsolicited requests
via private channels
“FDA recommends that sales and marketing
personnel have no input on the content of
responses to unsolicited questions or
requests for off-label information”
FDA Off-Label Guidance & Social Media
© 2013 Pharmaguy
Pharma is Overcoming Social Media Hurdles
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© 2013 Pharmaguy
Pharma is Overcoming Social Media Hurdles
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Period I: 54%Period II: 30%
Period I: 24%Period II: 42%
© 2013 Pharmaguy
Published all comments before reviewing, but reserved right to delete comments if offensive or mention ANY product.
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October 7, 2010
Evolution of Pharma’s Facebook Comment Policy
Alex Butler, Janssen Won the 2010 Pharmaguy Social Media Pioneer Award
© 2013 Pharmaguy
Sanofi-Aventis Vs. Patient on Facebook
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March 15, 2010
The pharmaceutical industry’s worst fear was realized when a “disgruntled patient” posted multiple adverse event messages and photos on the wall of a Sanofi-Aventis Facebook page (VOICES). The page did not have comments turned off and did not include any terms of use.
© 2013 Pharmaguy
Sanofi Didn’t Give Up on Facebook
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August 11, 2011
“Likes” have grown from 522 in January 2011 to over 6,700 in June 2013.
“Since we operate in a heavily regulated industry, we… must preview all messages.”
“While some messages may not be posted, we are listening and encourage you to continue sharing.”
Sanofi US Diabetes Won the 2012 Pharmaguy Social Media Pioneer Award
© 2013 Pharmaguy
I called this tweet “Sleazy Twitter Spam”
Challenge (US): How to fit benefits and fair balance in 140
characters or less?
Challenge (Globally): How to make it meaningful for patients
We’re Still Friends!
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First (& Only?) Pharma Rx Branded Tweet!June 18, 2009
© 2013 Pharmaguy
First (& Last?) Live Pharma Twitter Chat
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February 16, 2011
AstraZeneca hosted a one-hour chat on Twitter to raise awareness about helping patients save money through prescription savings programs.
Tony Jewell, AZ, won the 2011 Pharmaguy Social Media Pioneer Award
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December 13, 2011
The Prescription Medicines Code of Practice Authority
(PMCPA) ruled Allergan breached the Code on several counts
after an employee accidentally tweeted publicly about Botox
Employee violated Allergan’s "Global Social Media Policy”
that clearly stated "no Allergan employee might comment in a
social media forum about Allergan products or business
activity."
Should pharmacos make their SM policies public to be more
transparent & accountable?
Pharma Employee Tweet Problem
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A promise to visitors of SM sites you own or sponsor about how YOU will behave, not how you expect THEM to behave
Think of it as serving a similar purpose as your privacy policy Includes:
Your comment moderation policy; this requires more details than what has been seen to date
Rules for participation by your employees (reflects the internal policy that your employees are trained on)
Rules for participation by agents of your company (should be same as apply to your employees; trained on also)
Other “rules of engagement”; e.g., correction of misinformation
Thoughts on an Outward-Facing SM Policy
© 2013 Pharmaguy
What's Your Social Media Implementation Plan?
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© 2013 Pharmaguy
Is This the Typical Mobile Health App Developer Hired by Pharma?
Easy entry into mHealth offers incredible opportunity for innovation in healthcare; however, the open market comes with certain concerns, namely, “how credible are the apps I am (or my patients are) using?”
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Are developers knowledgeable about applicable regulations, laws, and pharma sensibilities?
© 2013 Pharmaguy
Undocumented & Untested(?) Medical Apps
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Psoriasis app by Janssen includes a “PASI” (Psoriasis Area and Severity Index) calculator
No citation of source used to perform calculation – was it the equation above?
No disclaimer such as "Persons using the data within for medical purposes should not rely solely on the accuracy of the data herein.”
Was the app tested and certified by a third-party?
Is it an “MMA” subject to FDA regulation?
© 2013 Pharmaguy
The First Ever “Dear Doctor” Letter Regarding a Mobile Medical App Recall
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Pfizer Rheumatology Calculator Most downloaded app tracked
by POCKET.MD (5-Star user rating)
Recalled via a “Dear Doctor” Letter in October 2011 because of "a bug in the app ... gives wrong results.”
© 2013 Pharmaguy
Reigning in the “Wild West” of Mobile Health Apps
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Inaccurate Health Apps Overzealous FDA Regulation? Good App Privacy Practices Test and Document Certification of Mobile Health
Apps Will Regulation Kill Innovation? Self-Regulation: Devil's in the
Details
Regulation of Pharma Mobile Apps Survey
© 2013 Pharmaguy
Survey Results
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© 2013 Pharmaguy
Self- Regulation of Pharma Mobile Medical Apps
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The pharmaceutical industry must police itself with regard to development of medical apps; e.g., Issue “Guidelines for Mobile Health Apps Developed by the Pharmaceutical Industry.” Some suggested guidelines, include: Apps should cite the source of the data used by the app and
include contact information for reporting errors. Call this a “Mobile App Adverse Event Reporting & Tracking” system.
Apps must be rigorously tested & certified by a third-party to ensure quality and accuracy.
Apps should include appropriate disclaimers and terms of use that the user MUST agree to before the app will run.
© 2013 Pharmaguy
Social Media Pharma Marketing Readiness Self-Assessment -- http://bit.ly/RocheItaly
Overcoming Space Limitations in Social Media; http://bit.ly/fdasmSpace Use code ‘FDA397’ to get it FREE!
Accountability for Pharma Content on Social Media Sites;
http://bit.ly/fdasmAcct Use code ‘FDA497’ to get it FREE!
Solving the Social Media Adverse Event Reporting Problem;
http://bit.ly/fdasmAE Use code ‘AE495’ to get it FREE!
Pharma is Overcoming Social Media Hurdles: Assessing the
Three Biggest Obstacles to Success; http://bit.ly/SMhurdles Use code ‘SMhurdleFREE’ to get it FREE!
Resources
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© 2013 Pharmaguy
Thank You!
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