Peter VigliaroloPeter Vigliarolo

There’s something the pharmaceutical industry can learn from this past year’s Presidential election: social media counts. It’s no secret that the pharma industry is risk-averse. However, it’s time for a change. As management guru W. Edwards Deming reminds us, “Change is not required. Survival is not mandatory.”

Peter Pitts, President and Co-Founder of the Center for Medicine in the Public Interest and Former FDA Associate Commissioner for External Relations said, “Social media just keeps on rolling along. And regulated industry just keeps falling further and further behind the curve.”

O'Dwyer's Oct. '17 Healthcare & Medical PR MagazineThis article is featured in O'Dwyer's Oct. '17 Healthcare & Medical PR Magazine

Don’t misunderstand the FDA

To understand why pharmaceutical companies have been slow to integrate social media into their media mix, it’s helpful to consider the perception of an indistinct regulatory landscape they must put aside. The good news is that the FDA offers specific guidance for pharma companies to participate in social media in a regulatory-compliant manner.

It’s not easy, but it is possible. And the benefits certainly outweigh the risks.

The FDA writes:

If a firm voluntarily corrects misinformation in a truthful and non-misleading manner and as described in this draft guidance, FDA does not intend to object if the corrective information voluntarily provided by the firm does not satisfy otherwise applicable regulatory requirements regarding labeling or advertising, if any.

To many in pharmaceutical company marketing and regulatory review departments, it may seem a distinction without a difference. But that’s a fundamental misunderstanding of the FDA’s mindset when it comes to social media. For example, in September 2008, the FDA sent out a warning letter regarding a YouTube video in which a paid celebrity spokesperson said that a drug had “cured” his disease (a decidedly off-label claim, shades of Dorothy Hamill and Vioxx).

And many internal reviewers industry-wide said, “See, you can’t use YouTube.”

Not so. It wasn’t about YouTube. If the content is non-compliant, then it is non-compliant, regardless of platform. As far as the FDA is concerned, platforms are agnostic. It’s the content that counts.

In March 2013, there was much angst over the FDA’s Warning Letter to AMARC Enterprises because of their Poly Mva Facebook page. Some concluded that this meant pharma shouldn’t be on Facebook. But the gist of that letter was that the company is marketing its veterinary dietary supplement as a human oncology drug.

In the letter, the Office of Prescription Drug Promotion spends a lot of time addressing the violative claims made on the company’s website and then—at the very bottom of the letter—addresses the issue of Facebook. The OPDP writes: We also note that your Facebook account includes a post, which was “liked” by “Poly Mva”:

“Poly MVA has done wonders for me. I take it intravenously 2x a week and it has helped me tremendously. It enabled me to keep cancer at bay without the use of chemo and radiation … Thank you AMARC.”

That’s a violative statement on any media platform. It just happened to take place on Facebook. “Liking” a violative third-party statement from your own Facebook account is violative behavior. You don’t have to be a rocket scientist to figure that one out.

As long as pharma companies communicate with honesty and integrity, they will be just fine on social media, which should be music to their ears, because the platform provides them an opportunity to innovate and reach customers in new ways.

Courage + conviction=content, creativity

For pharma industry social media pioneers, the payoff has been big. For example, Pfizer leveraged the power of community to create the platform Get Old, which centers around the fear of aging as well as wellness, disease prevention and treatment. The campaign fosters online discussion through content, forums and social media posts. The goals for pharma companies in campaigns like this are much bigger than an increase in product sales. It’s about shifting attitudes of not only their own companies, but becoming the hub of information for large populations of people.

The results have shown this to be true: several years later a poll conducted on behalf of Pfizer reported that the Get Old campaign produced a 45 to 55 percent uptick in how consumers felt about Pfizer’s reputation as a trustworthy company and also attributed to employee recruitment and retention goals.

Unbranded content communities can bring people together through powerful storytelling that isn’t possible with traditional marketing communications. Abb-Vie created StoryLab, which features researched, strategic articles that bring Abb-Vie to life through unbranded, engaging stories that matter to their key stakeholders.

To get their big idea off the ground, AbbVie created a focused content team that creates, develops, distributes and measures a wealth of stories and information across social platforms. It’s also worth noting their owned content also is often distributed and pitched to traditional media outlets, which truly makes StoryLab an efficient and integrated strategy—two keys to success.

One way to begin this new approach to content development is by creating a platform that focuses on the areas where your products specialize. This means shifting away from product-specific marketing to disease education and prevention information that helps audiences connect with one another. The most effective unbranded social media efforts evoke emotions and encourage experiences.

Not only will connective social campaigns elevate pharma companies to becoming educators and leaders in health, but they will also empower patients to become energized brand ambassadors. While pharma companies have been slower to dive into the innovative opportunities within digital campaigns, populations will continue to seek meaningful ways to connect with the companies that help improve their health and their lives.

It’s time for pharma to get over any remaining fears of social media, or mistakenly point to regulatory as a crutch. And companies shouldn’t just “keep the lights on” or “do it because we need a Facebook page.” They should dive headfirst into smart, engaging campaigns that create a platform around the needs of the customer. The industry’s hesitance means there is opportunity — right now — to win the communications in this space. If you keep waiting around, someone is going to beat you to it.


Peter Vigliarolo is a vice president of Padilla’s healthcare marketing practice and has more than 25 years of experience in pharma and medical communications.