“We’re not going to sit around as you drag your feet on the issue of healthcare social media content,” is what the DHC (Digital Health Coalition) appears to be telling the FDA.
Tired of waiting for the government agency to provide much-needed and long-awaited social media guidance to healthcare digital marketers, DHC (a group of 60 drug and digital health industry organizations led by Marc Brad, formerly of Manhattan Research) – have taken it upon themselves to get the job done.
In a meeting that took place in NYC on February 6, 2012 the group which includes big pharma names such as Merck, Roche, AstraZeneca, Lilly, Sanofi, GlaxoSmithKline, along with partnering agencies, Edelman and Digitas Health issued 7 Social Guiding Principles for digital healthcare marketers:
#1. Participate in Social Media
Regulated healthcare companies should endeavor to participate in social media as a means to promote public health, improve patient outcomes and facilitate productive patient-doctor relationships.
#2. Regulated companies not responsible for user-generated content
Regulated healthcare companies are not responsible for user-generated content online that they do not control. Regulated healthcare companies are deemed to “control” health and medical content if:
- it owns such health and medical content and has material editorial authority or
- it paid for the creation of such content and has material editorial authority over such content.
#3. Adverse events reporting guidelines
Regulated healthcare companies have a responsibility to report adverse events they become aware of. Regulated healthcare companies should follow the existing adverse event reporting rules in place at the FDA.
#4. Employee disclosure
Employees of regulated healthcare companies should disclose their material company relationship when posting comments/content or engaging in an online conversation relating to a company product or relevant healthcare issue.
#5. Timely communication response
Regulated healthcare companies should endeavor to respond to questions on sites they control within a reasonable period of time, and to implement reasonable measures to enable timely responses to crisis and emergency situations.
#6. Correct misinformation
Regulated healthcare companies should endeavor to make reasonable efforts to correct misinformation that is factually incorrect.
#7. Represent best interests of online patients
Regulated healthcare companies should endeavor to appoint employee(s) tasked with the role of “patient liaison” focused on representing the best interests of the patient online.
The idea behind this initiative was to get the conversation started about how the healthcare industry can evolve in the area of social media content. But it’s also a bold and admirable way of telling the government, “It’s not your job to tell us how to use social media to market our products.”
Given the feeble and failed attempt that the FDA made last December to respond to this issue, I believe DHC has positioned themselves as the guiding force in this important discussion.
What do you think: Will these guidelines issued by DHC change the conversations about healthcare social media or will the FDA have their say on the matter?