Updated: Jan 20, 2021
Should we comment on content produced by customers? A blogger just shared inaccurate or off-label information about our product – are we able to correct them? Working with influencers could be risky, what are the rules? What is the FDA’s latest position on healthcare social media guidelines?
As a marketing with years of experience working for medical device companies and law firms, I understand your merited fears and questions. To start, below are the basics of what medical device companies need to know about social media, but contact me if you want guidance in building your company’s credibility with social media and digital marketing.
Let’s get started with a few facts:
80% of individuals go to the internet and social media in search of information about their health.
88% of physicians use the internet and social media to research pharmaceutical, biotech, and medical devices.
42% of those looking for health information also search for health-related customer reviews.
As the facts state, having engaging social media pages give your company credibility and provides a way for doctors and patients alike to learn about new devices, treatment options, and innovative procedures. Additionally, people coping with disabilities or chronic conditions like heart disease, diabetes, or pain, and those who have been recently diagnosed are some of the most engaged social media users. They are seeking a peer community, treatment knowledge, and support from those who are helping to share their experiences hoping to make a difference for others in similar situations. Therefore, your medical device marketing or health-related company would be remiss if it ignored harnessing the power of social media to connect with potential and current consumers.
FDA Guidance on Correcting Independent Third-Party Misinformation
But with great online engagement comes great responsibility. People are expressing themselves online with pictures, videos, and text like never before, and can be amazing marketers for your product. However, they are most likely not medical or biotech professionals, and could also be sharing inaccurate or slanderous information.
To figure out how to manage all of this, let’s dissect what FDA Guidelines have to say about third-party information, such as User Generated Content (UGC) and how your company should correct any misinformation. You can read the full social media draft guidelines here and learn about specific advertising and promotion rules here.
In short, your company is responsible to ensure that all of your branded online content is completely accurate as stated by the FDA guidelines, “A firm is responsible for communications that are owned, controlled, created, influenced, or affirmatively adopted or endorsed, by, or on behalf of, the firm.” A firm is thus responsible for online communication made by its employees or any agents acting on behalf of the firm to promote the firm’s product.
In regards to all third-party content and conversations about your products, the FDA states that the draft guidance applies when:
“A firm is not responsible for a product-related communication that appears on (1) the firm’s own forum, (2) an independent third-party website, or (3) through other social media sites, and
The firm chooses to correct misinformation about its own product contained in that communication.
To put these words into real life, here are some examples:
Example: A firm becomes aware of a blogger who is posting inaccurate information about the firm’s product. The blogger does not have any relationship with the firm, and the firm is not responsible for the content of the blog. The firm may decide to attempt to correct the misinformation, but it is not obligated to.
Example: A firm hosts a discussion forum about its product’s FDA-approved use on its corporate website and does not participate in the discussion, but monitors the forum for profanity/obscenity. The forum includes an overarching clear and conspicuous statement that the firm did not create the content of the forum. The firm is not responsible for posts by independent third parties and can, if it chooses, correct misinformation according to this guidance.
If your company decides to comment on misinformation that was created by an independent third party about your product, as it is considered to be “appropriate corrective information,” your company’s communication should:
Be relevant and responsive to the misinformation
Be limited and tailored to the misinformation
Be non-promotional in nature, tone, and presentation
Be consistent with the FDA-required labeling for the product
Be supported by sufficient evidence, including substantiated evidence, when appropriate
Either be posted in conjunction with the misinformation in the same area or forum (if posted directly to the forum by the company), or should reference the misinformation and be intended to be posted in conjunction with the misinformation (if provided to the forum operator or author); and
Disclose that the person providing the corrective information is affiliated with the company that manufactures, packs, or distributes the product.
Protect the Image and Best Interest of Your Company: Pinned Posts, About Sections, and Disclaimer/FAQ Blogs
Creating informative disclaimers and policies can proactively answer consumer questions or lead them in the right direction, protect your image and best interest, and show transparency in how your company monitors your online channels. A few ways to do this are:
“Pinned to the top” post on your Facebook, LinkedIn, and Twitter pages. This can include a brief statement about your company, how to contact patient/customer support, information about new products, and a link to a “Social Media Guidelines” page on your website. For Instagram, you can use the link in the profile section and include extra information in a “Featured Story.”
Social Media Guidelines page. This could include an FAQ page about how your company responds to comments seeking medical advice, questions, and complaints about products, comments that contain personal info, how to contact customer support, A great example can be found on the Boston Scientific’s website.
Facebook and LinkedIn About Section, Facebook’s “Story/Who We Are” Section, and Twitter Profile. All of these sections can be alternative places to showcase your social media guidelines.
Additionally, all companies, not just those in the medical device industry, should have clear social media guidelines that all employees are fully aware of. This can help prevent negative outcomes from employees using social media while being associated with your company.
In summary, here’s the social media doctor’s prescription.
Be socially responsible on social media. Proactively engage with potential and current customers in creative ways. Remember: you do not legally have to correct misinformation from independent third-party content.
Content that is controlled by your brand is your responsibility; ensure that it is accurate and that you have a social media marketing strategy
Be proactive and transparent; list your guidelines in visual locations.
Be human – not a sales machine; talk to people like a friend, figure out how your product can help with their condition.
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