Social media plays an increasingly significant role in the US healthcare system. According to a recent poll, the average American
spends more than 52 hours per year on the Internet looking for health information, but only visits the doctor three times
per year. While 53% of users rely on the health information hub WebMD, others rely on more general social media sites like
YouTube (12%) and Facebook (10%). Only 9% of Internet users rely on pharmaceutical companies' sites for information.
In light of the growing influence of social media, pharmaceutical companies may be considering their options when it comes
to such interactions. But for these organizations, entering the social media scene is not as simple as just creating a Facebook
page or learning how to tweet in 140 characters or less. Rather, social media poses a regulatory and litigation maze that
must be carefully navigated. Here, we provide some insight into the most pressing questions companies are, or should be, asking
about social media.
1. Should my company increase its social media presence?
Most pharmaceutical companies have only a limited presence on social media sites. In fact, according to a study released by
the IMS Institute for Healthcare Informatics, "among the 50 largest [pharmaceutical] companies, half still do not use social
media to engage consumers or patients." And "only 10 of the top drugmakers have availed themselves of all three of the most
widely used social media channels—Twitter, Facebook, and YouTube." Some companies have Facebook pages but include no product
information on them, and many explicitly inform visitors to their Facebook pages that any comments mentioning products may
Yet, pharmaceutical companies are the logical source for the most current information about a particular product. The lack
of clear regulatory guidelines may be part of the reason companies have been reticent to broaden social media interactions
Companies may want to increase their social media presence for many reasons beyond marketing, not the least of which is to
provide the public with clear, unified information on the company and its products. In the absence of information directly
from the company on an official or authorized social media page, companies may be able to do little to counteract potential
misinformation arising out of the growing amount of anecdotal information available through mainstream social media sites.
This could give rise to reputational harm that companies can do little to address after the fact.
2. Does my company's Facebook and other social media presence provide fair balance?
Recent FDA activity, including the agency's letters to Institut Biochimique (IBSA) and Akrimax Pharmaceuticals and to Amarc
Enterprises teach us that the FDA is indeed watching what pharmaceutical companies post on social media sites and is continuing
to enforce existing advertising guidelines, including fair balance. Companies have struggled with finding ways to meet those
requirements on these new platforms, and FDA has provided only limited regulatory guidance thus far. While it is still very
unclear what makes for best practices in this space, once can safely assume that until there is new guidance, companies will
need to provide the same fair balance information about potential risks and side effects in every posting as they would in
any other marketing context.
FDA has not yet provided any indication that the fundamental fair balance rules will change as social media changes. However,
guidelines are expected this year to provide guidance on "Presenting Risk and Benefit Information for Prescription Drugs and
Medical Devices" on social media platforms "with Character Space Limitations."