In June 2014, FDA issued some social media guidance for medical device and prescription drug companies.
The title is ironically long. “Guidance for Industry: Internet/Social Media Platforms with Character Space Limitations—Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices” has 171 characters in it (including spaces), so we wouldn’t be able to talk about it on Twitter, I guess.
Besides, “Medical Device Marketing in 140 Characters” has a better ring to it, if you ask me.
My comments focus only on medical device implications. You can download the complete guidelines (with my highlights to emphasize areas of interest) below.
Topline It For Me
In a sentence, the FDA social media guidance says if you need more room to reveal material facts than the medium allows, don’t use the platform.
The Main Points
1. It’s Every Time. Every communication you make has to stand on its own. From guidance,
“Benefit information should be accurate and non-misleading and reveal material facts within each individual character-space-limited communication (e.g., each individual message or tweet).”
2. Disclose the Risks. If you’re not cleared for use, for example, you must say so. Each time. From guidance,
“Benefit information should be accompanied by risk information within each individual character-space-limited communication.”
3. Not Enough Room? You’re Not Excused. From guidance,
“If an accurate and balanced presentation of both risks and benefits of a specific product is not possible within the constraints of the platform, then the firm should reconsider using that platform for the intended promotional message.”
• Scope. The guidance encompasses “online paid search (e.g., “sponsored links” on search engines such as Google and Yahoo, which have limited character spaces.” It does not encompass Facebook, LinkedIn, websites, or other online media the Agency believes “do not impose the same character space constraints as online microblog messaging and online paid search.” But the guidance kind of does encompass media with ‘character space constraints’ because the “Every Time” and “Disclose the Risks” rules still apply.
• Hyperlinks Encouraged – to Dedicated Landing Pages. FDA favors sending readers to your website for more information – but don’t make readers have to find it. That is, sending them to the company’s homepage won’t cut it. Instead (and it’s a good medical device marketing practice anyhow), create a dedicated landing page that relates specifically to the content you “micro-shared.”
• No URL Funny Business! In our character-constrained environment, the Agency is fine with URL shorteners (bit.ly, ow.ly, tiny.url, goo.gl) to save space. But don’t get cute with the URL or domain name to squeeze in a suggested benefit. From guidance, the fictitious “BestCancerCureDrug.com” is a clear violation.
(aka “What’s your take, Joe?”)
A whole bunch of “FDA Gives Guidance on Social Media” articles were published with an air of “Finally!” – as though this was a big event.
I didn’t see it that way.
The guidance is a logical extension of 2009’s “Presenting Risk Information in Prescription Drug and Medical Device Promotion.”
No, the main points I’d convey about social media for medical device companies are the same this week as they were last.
1. Leapfrog Your Scared and Uninitiated Competitors. Maybe out of fear, maybe for lack of support or resources, many of your competitors aren’t using online media effectively. That’s an opportunity for you to gain a greater share of voice.
That is, if you’re willing to put in the effort. A half-hearted social media effort on your part will render half-hearted results (and probably less than that).
2. 140 Characters are Plenty. Micro-communication helps direct traffic to your site and most URL shorteners consolidate your hyperlink down to 20 or fewer characters, leaving you with 120 on Twitter. That will suffice in most cases.
3. Not Everything is a Claim. If the only message you’re sharing is “my product does this” and “my product does that,” you’re not going to engage anyone. You can share related news stories without making claims, such as the local coverage of the life-saving use of a school defibrillator, or the testimonial from the single-sided deaf patient who hears out of her left ear for the first time.
What do you think of the guidance? Are you using social media?
Related Article: Low Effort, High Payback Twitter Tips for Busy Marketers and Reps
Thanks for reading. If you got something out of it, you’ll probably appreciate my 25-page ebook, “Steal These Ideas: 10 Proven Lead Generators for Medical Companies.” Download it for free.