How Pharmaceutical firms can use social media within the regulatory framework

Ranking of 25 pharmaceutical firms scored for their use of social media
Twitter is by far the most popular social medium for pharmaceutical firms
  1. FDA clarifies the difference between unsolicited and solicited requests in the social media. For example, a question about off-label use posted on a pharmaceutical company’s web site, whether directed to the drug maker or others visiting the site, is an unsolicited request. On the other hand, if a pharmaceutical firm encourages people to post content on social media using one of its products and the content prompts questions about off-label use, this would be a solicited request. The FDA may consider solicited requests evidence of a firm’s intent that a drug be used for off-label purposes.
  2. The FDA also distinguishes between non-public and public unsolicited requests. For example, a phone call to a company’s medical affairs department is a private request, and the response should be provided only to the individual in a one-on-one communication. A question about off-label use that is posted on an social media forum is considered a public request, and if a company chooses to respond, it should give contact information only; anything else could be misinterpreted by others in the forum as off-label promotion.
  3. The FDA also encourages drug companies to respond to unsolicited requests that are made in a public forum because other forum participants might not provide or have access to the most accurate, up-to-date information.
  4. Responses to unsolicited requests should not be promotional in nature or tone, and they should not provide links to promotional content.
  5. Companies should respond to unsolicited requests only if they pertain to that company’s own named product.
  • ABPI has published code of practice for pharmaceutical promotions which lays out the guidance for promoting prescription drugs
  • Pharmaceutical firms cannot promote prescription-only medicines and those that haven’t received marketing authorisation to the public; but facts may be shared.
  • The ABPI differentiates between proactive information which is pushed at the recipients for example Ads, reference information and reactive information which is supplied to the public in response to a direct request. Furthermore, the company must disclose the sponsoring of any material.
  • Pharmaceutical firms must record all adverse events and product complaint data, which may be reported to the medicines and healthcare products regulatory agency (MHRA) if reporting requirement are met.
  • Listening involves monitoring social media sites, to allow a company to ‘listen to’ what the public discussions on social media about the company, diseases, conditions and the treatment options.
  • Broadcasting involves companies initiating one-way communication to share messages with the public, where interactive dialogue is not permitted or practical.
  • Engaging involves exchanging messages and participating in an interactive communication with the public.
  1. http://www.abpi.org.uk/our-work/library/guidelines/Documents/ABPI%20Guidance%20on%20PV%20and%20Digital%20Media.pdf
  2. https://www.fda.gov/downloads/drugs/guidances/ucm401087.pdf
  3. https://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm285145.pdf
  4. https://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm381352.pdf
  5. https://www.fda.gov/downloads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm401079.pdf
  6. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3351868/

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sid dhuri

sid dhuri

I am data scientist by trade. I love to write about data science, marketing and economics. I am also the founder Orox.ai a marketing ai and automation platform.