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Pharma companies would do well to proceed with extreme caution when entering the blogosphere
Visionary companies across the business spectrum are reaching out to consumers through official, corporate-authored blogs. It's a fast, inexpensive way to bring the brand message to tech-savvy customers around the world. Blogging is an easy marketing method for any industry—except, of course, for pharma, which has to contend with a veritable minefield of potential blog-related troubles.
Fundamentally, blogs represent the most extreme form of unregulated communication available—a style of unchecked discourse that flies square in the face of how pharmaceutical companies have been structured to behave and communicate. This structure is borne from a need to comply with strict government regulations that exist to ensure that pharmaceutical companies promote their approved products in an appropriate and responsible manner in order to ensure the public's health and safety. To date, FDA has yet to issue guidelines that specifically address how companies should communicate on the Internet. The agency has, however, stated that online communication should be governed by the same principles that apply to television and print advertising. This guidance was adequate back when a Web strategy consisted of a product Web site that was little more than an online brochure. However, the new generation of Web services has created an whole new set of challenges for the pharmaceutical industry—an industry that, like most others, is keenly interested in listening to, communicating with, and engaging its customers.
The primary challenge for pharma in this arena is the concern that a commenter may mention an adverse event on a company-owned blog. If that were to occur, the company would be required by FDA to report the event. Reporting an adverse event requires "an identifiable patient," but since most comments tend to be posted anonymously, this presents the first of many problems. Capturing significant information about a person raises questions of patient privacy. When an individual discloses his/her health condition on a blog, it is now public—and if the blog is owned by a pharmaceutical company, that company could be accused of violating an individual's privacy simply for having facilitated the disclosure.
Because the company is ultimately responsible for all blog posts and comments, it should take care to implement safeguards. All submissions absolutely must be reviewed by the company's internal medical, legal, and regulatory teams prior to publication. Unfortunately, an internal review process may take days or even weeks, detracting from one of the most appealing factors of a blog—the freewheeling, ongoing dialogues and debates that people have come to expect from this medium. The lengthy lag time between comment submissions and public postings, coupled with the restrictive rules on what can and can't be posted, will certainly make a pharmaceutical-sponsored blog a difficult enterprise to launch and maintain successfully.
Many complicated issues surround pharmaceutical-owned blogs, so it's easy to understand why most companies have not launched blogs where people are allowed to post and comment freely. However, that doesn't mean pharma should give up on blogs altogether.
There's no need to reinvent the self-protection wheel. Pharmaceutical companies already have processes and procedures in place for dealing with adverse event reporting through toll-free numbers and such Web sites as FDA's own MedWatch (http://www.fda.gov/medwatch). Here are a few tips for how to create a positive user experience while limiting exposure.
Communicate rules With any feedback form, provide users with very clear "rules of conduct" that explain what they can and cannot say in a post.
Apply filters Wherever a user is presented with an open-text form, implement filters that scan the specific terms or phrases that are being keyed in and trigger an immediate "cannot accept this message" warning that explains to the user in clear language why this information is not allowed on the site.
Set expectations Explain to users the process involved in approving feedback and comments so that they will understand why their feedback isn't immediately posted.
Create policies Establish a policy on editorial control of blog comments. Companies must develop proper disclaimers, site-use policies, and internal policies and procedures to avoid inadvertently posting adverse events or endorsing off-label uses of products that appear in the discussions.
In addition to the examples listed above, there are also ways that companies can leverage blogs. If your goal is to create and maintain a blog for your company or brand, here are a few approaches you might consider:
Blog Ad Networks
Implement tools and services to monitor blog conversation trends. Uncovering key topics surfacing within the blogosphere may inform content updates that could be made to a Web property to address a specific issue or concern in the blogosphere. While some companies fear that aggregating verbatims from the online world would also mean catching a few nasty fish (e.g., reports of adverse events), remember that unless the blogger provides sufficient information about himself and the adverse event, it's highly unlikely that a company will be required to act upon these posts. However, a trend of similar posts could also be viewed as a "safety trigger," and it might be wise to investigate this potential risk sooner rather than later—including alerting FDA via a letter. Sufficient data could prompt the company to create dedicated postmarketing studies that will explore this issue in more depth. Yes, it could be costly, but perhaps not as costly as having a drug pulled from the market.
There is no magic formula for implementing a blogging strategy, nor is there one strategy that will work for all brands. The right strategy for your brand depends on the unique needs that are specific to your product, the disease state it addresses, and your target audience. Like all other strategies, it starts with a plan. Part of the plan must account for possible backlash and failure. Until the industry is willing to take a risk, it will not make the mistakes necessary to move forward and achieve success. That, perhaps, is the biggest conundrum pharma wonks face—not just as healthcare marketers, but as human beings.
Fabio Gratton is the chief innovation officer and a founding partner of Ignite Health. He can be reached at firstname.lastname@example.org