Sep15

Responsive Web Design in Pharma

CREATIVE MOBILE BLOG PHOTO2Data is showing that we are using smartphones more and more for everyday items—searches, purchasing consumer products, travel, weather, and World Cup updates, just to name a few.

We also see smartphone users searching on prescription drugs. Healthcare professionals (HCPs) are using mobile more in their practices, yet the branded drug websites are not optimized for viewing on their phones. We see this as a missed opportunity to provide the information need to the device being used.

 

In the pharma space, we are seeing an uptick with websites moving to a responsive design methodology with consumers—but not with HCPs. We need to understand how HCPs are using their device in the office. By thinking mobile first, we can better serve their needs. Focusing on the user experience with information architecture and content strategy, we can provide the right information to the user, spanning across multiple devices.

 

This would be extremely helpful for our HCPs. If I need to look up a dosing chart for a specific drug while in the exam room, I should be able to use my mobile device to view and interact with the chart. Later, when moving to the desktop, I should have the same content and experience.


RWDP

The chart to the left is a good example to see how content can be organized from the desktop to smartphone. Take note of the design grid and how it responds to device screen sizes.

 

A good example in the pharma space is Forum Pharmaceuticals (forumpharma.com). Simple, easy to navigate, and the experience stays with you through the multiple devices. This makes for a happier end user.

 

 

 

 

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Sep11

Are Apple’s new offerings really ready for healthcare?

RPBLOGApple fans were waiting with bated breath for this week. And in usual Apple style, the company did not disappoint the vast numbers of people who eagerly sat through a staged presentation of the new products Apple will be foisting upon us in the next six months.

The new iPhone 6 is a sleeker, stylish phone with a bigger screen, a plethora of new groundbreaking apps such as Apple Pay, and powerful technology that could make the phone even more personal than it is now.

And as if that were not enough, Apple provided a double-whammy by showcasing the new Apple Watch, a truly innovative and stylish mini device that will change the simple task of telling the time.

With these two new devices, Apple also began to stake a claim in the health and wellness arena.

Let’s take the phone. It comes bearing the next generation of Apple’s powerful M chip—the M8. This chip enables Apple to turn the iPhone into a fitness tracker. The next generation motion coprocessor and sensor will know whether you’re riding a bike, running, or speed walking. It will also be able to estimate distance as well as how far you’ve gone. Finally, it will track elevation, thanks to its very own barometer, which will pick out your relative elevation by measuring air pressure.

All of this data will be collected by the new HealthKit app with powerful and intuitive dashboards and displays to help the owners of the device to begin tracking and analyzing all manner of activities.

The Apple Watch enters a largely unregulated personal health tracker business, taking on Fitbit, Jawbone, and other wearable devices. This is a powerful device. It is a pedometer, a heart-rate monitor, and it comes with a robust array of fitness tracking features, including “rings” to track your movement.

The Move ring will track your normal amount of activity, such as walking. The Exercise ring will track all manner of exercise routines, and the Stand ring will measure how long you stand or sit during the day.

But the watch also becomes your personal coach and will give you customized reminders to reach fitness goals. It will have its own Workout app, which will measure calories, time spent working up a sweat, and a variety of other activities. Finally, it will also gently nag or encourage you toward doing things more slowly than you planned. All of this will be shared with the HealthKit app.

Apple plans to offer a sports version of the watch, which comes with an alloy case that’s 60 percent stronger than the regular version.

The Apple Watch looks like it will become a serious contender in the fitness tracking market, but the steep pricing may make other fitness trackers more appealing to people.

From a regulatory perspective, the Apple Watch, while not being deemed a medical device by the Food and Drug Administration (FDA), will be watched closely. The personal health data collected by individuals for their own use is outside the federal laws controlling the use of patient information.

This collection of data opens up a debate on privacy, and as this is health-related data, there will be extra scrutiny on how this data is collected and used, and more importantly, who has access to it.

However, the Feds are closely watching this fast-growing market. The FDA has already issued a list of mobile applications it is watching closely. The list includes software used by individuals to track and log personal data on exercise, food consumption and sleep patterns, and to make suggestions about health and wellness.

The major issue for privacy advocates will be how this personal data is used by the device makers and developers of apps. How marketing uses this data for profiling and targeting will become a place for regulators to identify safeguards.

Apple is also doing its bit and has made it clear to developers of health apps that it wants to protect privacy. This comes on the heels of the broadly covered celebrity hacking debacle that occurred a few weeks ago, opening up a debate about the collection and backup of data from mobile devices that synchronize with the cloud.

Last week, Apple updated its guidelines for health app developers, stating that apps working with HealthKit may not use the personal data gathered for advertising or data-mining uses other than for helping manage an individual’s health and fitness, or for medical research.

The guidelines also say that app developers cannot share data with third parties without the user’s consent.

It will be interesting to see how the FDA, as well as privacy bodies in the more stringent and regulated environments in Europe, deal with the brave new world that Apple is forging for us.

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Aug27

Isn’t Patient Centricity What Pharma Has Been Doing for Years?

TinaWoodsGraphic2Patient centricity is the new buzzword. Most of our pharma clients have patients at the heart of their corporate vision and mission, and say that the patient voice drives everything that they do. But what does it really mean to be truly patient centric?

At the recent EyeforPharma Patient Summit in London, there was a lot of talk on organising companies around patients rather than brands. And this is not surprising given that a true understanding of patients’ day-to-day needs and how they behave in the real world, as opposed to trial conditions, is critical to developing successful new products over the long term.

As digital channels, including mobile and social media, continue to democratise communication networks, pharma cannot afford to pay lip service to the increasingly powerful patient voice. They need to get used to the idea of patient opinion leaders shaping the future via patient-driven networks. For example, developing patient champions who will talk about their illness will be essential in establishing disease awareness.

The notion of supported self-management and how pharma should/could be involved is a hot topic. It is important to develop integrated, personalised patient support programmes to facilitate quality interaction between patients and stakeholders (including caregivers and family members) along the patient journey. The goal should be to provide innovative solutions around patient needs and wants—to deliver an improved patient experience, addressing patients’ individual beliefs, behaviours and goals as they are on their personal and emotional journey.

Meaningful patient insight is at the heart of any patient-centric strategy. Understanding the lived patient experience, “walking in the patients’ shoes,” is the key to deriving these insights. Anything else is just observation. Unless they have been patients themselves, even healthcare professionals are merely observers and cannot truly understand the lived patient experience.

True patient centricity is in the process of being defined, not by pharma, nor by healthcare professionals, but by the patients themselves. Is it any wonder that people are saying that “true patient engagement is the blockbuster drug of the century”?

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Aug21

Adherence Is a Dirty Word

Adherence Picture BlogInstant gratification is not fast enough.

That’s the short answer to what derails (or drives) patient engagement. It’s simple really—you’re asking someone to change their routine, visit the doctor, spend their money, change their lifestyle—for something that doesn’t necessarily have a recognizable payoff tomorrow.

We design programs, apps, and all kinds of resources to “encourage adherence,” but they may only add to this burden. So what, exactly, is that burden?

Try it yourself.

That’s what patient educator and advocate Catherine Price (@catherine_price) has folks do. Dubbed the Tic Tac Challenge, participants use Tic Tacs as placebo pills, to see what it REALLY takes to remember to take your meds.

I organized a small Ogilvy Payer “Adherence Challenge” among my Payer, Creative and Shared Service colleagues, with the help of our fabulous summer interns. In the true spirit of a new prescription, each person got a script (with varying dosing regimens) which was filled at the “intern pharmacy.” Some scripts even had a prior authorization (PA) hurdle, which required a trip to our Director of Operations to answer SOX questions, to mimic the health plan benefits investigations and appeals process.

So how did we do?

Well. I didn’t even fill my script. The PA hurdle I landed with proved too great a barrier in my schedule.

Others’ success ranged from “almost compliant except for one travel day” to sporadic compliance, and some reported back compliance—but only on workdays when it fit into a routine. Variations on time of day, taking with food, or polypharmacy had a noticeable impact on the adherence burden. While some had routines or other reminders to help them along, no one was 100% compliant. With so much going on in our lives, it’s no wonder it’s easy to forget.

 

What’s the answer?

Well, there is no single solution. Merely knowing that “you have to” is not enough. There needs to be a reason you WANT to take a pill every day. Health needs to be integrated into life, not an add-on to it. HCPs need to speak the language of their patients— à la shared decision-making—to truly engage patients toward the benefit that adherence gives them in their life. Technology, while helpful, cannot solve everything for the unmotivated patient (hit that snooze button again!). Far-off benefits are strongly outweighed by what the patient needs/wants/feels right now.

For us, this is just something to keep in mind as we design apps, resources and CRM programs. Simple, integrated, and aligned with the patient’s goals is the mantra I will be marching forward with. A patient cannot just be adherent (a supporter or follower). Instead, a patient must be an enthusiast—active in his or her health interests.

 

These insights came from my attendance at the Patient Adherence & Access Summit this past June. If you would like the full write-up from the summit, just shoot me an email and I’ll happily send it over!

claire.pisano@ogilvy.com

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Aug13

Courtesy: A Workplace Essential

Thank You TypewriterThe rules of courtesy were programmed into my brain from a young age. The power of “please” and the testimony of “thank you” are the gods of courtesy, but like all greatness, there’s more than meets the eye. These words represent the beginning and the end of all things courtesy. Just as in life, the most important parts of courtesy are not the beginning (please) or the end (thank you), but what happens in between.

Growing up playing sports showed me how to work with others in the pursuit of something greater than myself. Working at OCHWW over the last few months has shown me that my coaches prepared me for what most new college grads consider “real life” more than I thought. At an advertising agency, everyone relies on others to accomplish their goals. The creative team might be the players on the ice (I played hockey), and the account team might be the coaches. Without these two teams working in tandem, the work does not get completed. If the creatives are the players and the account teams are the coaches, then the clients are the general managers and owners. All are in the pursuit of one thing, the Stanley Cup of advertising: a great ad and maybe a few accolades to go with it.

Now, how does all this work get done? With the help of courtesy, of course. Here’s an example: I pass the puck to you. You need to get it back to me for us to score. Simple, right?

Here’s another: I email you in the morning. “Can you please let me know where project “Protect the Puck” is on the timeline and when I can expect to receive it? Thank you.”

If I don’t hear back from you in a timely fashion, it might paralyze me. By simply taking a few seconds to respond, it helps me to prioritize my work that day and solve problems, finding a way to work around the situation, or work with you to complete the project. I understand that you are busy. We all are. But as a professional you know that all your colleagues are relying on each other to get things done. By giving your team members a quick heads-up, you help them do their jobs better. You also relieve some tension in your own day because it forces you to prioritize too.

There are other benefits that come from workplace courtesy too. When you are kind to and considerate of your colleagues, that will come back to you. The easier you interact with people, the more likely they will be to help you in a pinch if they can. In turn, this makes your team stronger because you can interact with great candor and camaraderie. A strong team in which everyone is working in tandem is tough to beat.

If you do not carry yourself with great workplace courtesy, may the gods of courtesy smite thee!

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Aug7

We Meowed at Lions Health in Cannes

cannes meowCan you believe it’s been almost two months since the very first Lions Health at Cannes! I am actually kicking myself for not writing this sooner, but you know how it goes.

Overall, I thought the standard of work was high, and that’s what you would expect for this type of event. I wouldn’t say that there was a new standard set, but there were definitely new players—non-healthcare agencies that haven’t been bound by medical departments or the weight of the past.

Cannes Lions Health is putting healthcare advertising and communications on the world stage, and I think this is great, but the playing field has just gotten bigger. So us healthcare folk need to stretch ourselves even more and deliver ideas that aren’t a print ad, e-detail aid or a direct mail series. We need to look outside of this and step away from the pharmaceutical/health look, feel, taste and tradition.

I am proud to say Ogilvy CommonHealth Australia did just that with “Cat Ramps,” a little ambient idea that set out to raise awareness of cat osteoarthritis.

Instead of doing posters or an ad, we created a series of specially made ramps with website activation that were placed in Hyde Park Sydney on one day. Park visitors and city workers could interact with the ramps, activate the mobile website, learn about the disease and the signs to watch for, and potentially seek a management plan from their local vet.

The traffic to the website exceeded objectives threefold. Just under their monthly hits was achieved in one day.

Even though we only made it to Finalist, it was a big achievement given the 1,400 entries from 49 countries.

But the biggest achievement was getting this idea signed off and up and running.

So this little meow will hopefully turn into a big roar for Ogilvy CommonHealth Australia as we start our journey toward the next Lions Health in 2015.

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Jul30

Numbers Don’t Lie—But They Could Be Trying to Tell You More

data tabletAn advantage of analytics that is often extolled or capitalized on is the sleek, easily consumed result at the end of miles and miles of data. It is an alluring power, to be sure, and the ability to see past the noise to extract core performance metrics is certainly foundational. Practically, however, these extractions may lull one into seemingly natural simplifications of data in order to provide neat, packaged numbers.

Analytics is not merely a mass of raw data; it is the underlying story being told by the data and it is the story that is meaningful. In essence, context imbues the easy and commonplace metrics we use and rely on with impact and meaning. Merely looking at just one aspect of performance can even be detrimental, as it blinds us from other motivating factors.

In fact, in an increasingly digital HCP world where 98% of physicians use the Internet for professional purposes [1], the task of understanding and connecting with this audience has grown more and more complex.

Specifically, with regard to digital web analytics, some of the primary and day-to-day concerns revolve around site performance and content engagement. What many of these issues generally boil down to are fairly straightforward answers—number of site visits and interest in specific site content.

Volume of site traffic is, independently, a rather inert number that can be incredibly misleading. High numbers one month followed by a much lower volume the next would assert that website performance has declined in terms of site traffic—but placing these numbers in context of another metric could change the view entirely. Looking at visits in light of bounce rates could inform us that a far smaller percentage of visits bounced in the latter month. Time on site might stay the same from month to month, but if page views per visit decrease, then more time is being spent consuming content on each individual page (on average), delivering an entirely different message once a corollary metric is introduced. The goal, after all, is to deliver the right message to the right audience, at the right time. A larger audience might not necessarily be the right audience, and so the quality of a site visit or a digital imprint is affected by and affects a multitude of other elements.

The benefits of exploring the connection between metrics are the models that emerge from the analysis, which in turn allow us to make more surprising and valuable insights. A top-line glance may miss or overlook these connections in its urgency to survey surface-level movements or trends; breaking down site referrals by traffic drivers might display which sources of site visits are the most prominent, but aligning these sources with other factors could reveal that certain segments are more likely to convert (download materials, sign up for accounts, order samples, etc.) and thus lead to immediately effective and actionable conversations.

At any point in a venture where data is generated, or can be generated, analytics can explain, evaluate, and optimize. No one part of it should be taken in isolation from the others, and this is no less relevant to the practice of analytics itself.

It is imperative that analytics never be stripped down to mere metrics, but live and thrive in a much larger framework.

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Jul23

Curiosity Taught the Cat

6568523“An endless trail of ideas floats in the ether. You will only see them if you are curious.” I read this in The Eternal Pursuit of Unhappiness book all Ogilvy employees know and love. It got me thinking about curiosity—one of David Ogilvy’s eight habits. Is curiosity an important skill to have in the healthcare communications field?

They say curiosity killed the cat, but I believe curiosity taught the cat (plus, don’t cats have nine lives?). From interning at Ogilvy CommonHealth in the summer of 2014, I can see why curiosity is a must skill to have. In the rapidly changing healthcare field, there are so many aspects to be familiar with. For starters, healthcare reform is constantly changing with new laws and regulations. The pharma market is always evolving with new drugs and medications for patients. Also, the aging population is causing shifts in the demand for certain drugs, devices, and medications. There is always something new you have to keep your eye on in this field, so unless you have the curiosity, you are likely to miss current trends in the healthcare field.

Curiosity as a student

Curiosity helps people grow. In college, I’ve learned that curiosity is best practiced by taking chances. Each semester I believe it is important to take a course that is unrelated to a major or minor. It helps students think outside of the box and get a different understanding about various topics. I’ve noticed that the students who take chances like this in college are the ones who build a well-rounded background.

Curiosity at Ogilvy CommonHealth

I believe being curious is important at Ogilvy CommonHealth too. However, instead of just giving my reasoning, I will share the viewpoints of two others here at Ogilvy:

Jamie Fishman, senior account executive in Payer Marketing, believes we can’t be proactive in this evolving market or even provide value to our clients if we are not curious. There is a difference, however, between being proactive and being curious. Jamie states that questioning or looking into what is known is being proactive, while questioning or looking into what is unknown… that is true curiosity. When we research our clients and understand their industry, we are able to be ahead of the game to serve our clients the best. Jamie stays curious by reading about the work she is involved in and sharing articles with others in order to spark their curiosity. It is no surprise that she believes it is an important skill as well.

Jenita McDaniel, EVP director of operations in Payer Marketing, takes the importance of curiosity a step further. “The people that are curious change the world,” she said, “if our ancestors were not curious, we would not even be here.” It goes to show how brilliant minds are curious. In fact, if our ancestors were not curious, would they have taken risks to explore new life? Would they expand their knowledge to explore the world? Jenita also believes great ideas stem from curiosity; it helps us understand our clients and serve them to the best of our ability. Additionally, Jenita went on to say that curiosity is about taking chances, and those who are curious constantly push the envelope.

I’ll end by sharing a few tips I’ve learned from Jamie and Jenita to help you be more curious:

  1. Read. A lot.
  2. Share what you read with others. Including clients!
  3. Ask questions.
  4. Learn (from any opportunity).
  5. Teach.

I’m sure the more these five tips are practiced, the more curious you’ll become, thus achieving greater results, enhancing intellectual growth, and practicing professionalism.

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Jul16

“It’s not a tumor!” Cyberchondria and the Diagnoses That Spawn From It

2287994It’s 7 am; I’ve just awoken. My eyes are adjusting and I’m sprawled in my bed. My mind is not coordinated enough to move my body. Man, I am exhausted, I think. How is it only Thursday? My head kinda hurts. Good God I have to pee. I could probably snooze for like fifteen more minutes, if I shower quickly. Seriously, my head hurts. Right in my left temple. I must have slept wrong. I don’t remember hitting my head or anything. I sit up abruptly. Oh Lord now I’m dizzy. I’m dizzy and I have a sharp pain in my temple. Holy crap what if it’s a tumor, or an aneurism. When I did those brain cancer interviews last year they all said they woke up with headaches. This is that exact same situation. Where’s my iPhone? How do you spell meningioma, two “n”s? No, one “n.” Thanks Google. Okay WebMD…signs and symptoms…yup, here it is. Headache: check. Dizziness: check. Weakness in arms and legs: now that you mention it, I can barely hold this phone it feels so heavy. Blurred vision: that one’s probably next. Yup. It’s definitely a meningioma. I should call my dad. Just tell him I love him.

But just as Arnold said, it’s not a tumor. And while that example might be a tad exaggerated, I’ve certainly had this type of half-awake, neurotic, cyberchondria once or twice in my life. Though the above situation was more likely caused by one too many glasses of wine and a refusal to admit to a hangover.

Nevertheless, the concept of self-diagnosis is an ever-growing phenomenon in this digital age. According to a survey conducted by The Pew Research Center, over 35% of Americans in 2012 had gone online to diagnose themselves, and more than a third never confirmed that diagnosis with a doctor. What’s worse: some 30% of self-diagnosed women have admitted to purchasing and consuming medication for their supposed illness, without a consultation. That’s the part that shocks me. Sure, I might convince myself I have a pet-dander allergy, but that does not mean I trust my diagnostic abilities enough to assault my leg up with an EpiPen.

But it does happen. And those working in the healthcare industry appear to be the worst culprits—after all, we live and breathe this stuff; it shouldn’t be hard to tell if we have chronic migraines, or insomnia, or endocarditis, right? Our increased level of knowledge mixed with a splash of arrogance is just enough to convince us that there is little a PCP’s gonna tell us that we don’t already know.

And while the hyperbolic, often terminal, self-diagnoses are more my style, physicians say they are more concerned with the prevalence of under-diagnosis among systematic Googlers—as we all know, convincing oneself that a rash is just a rash, or numbness is just an innocent side effect can have irreparable effects.

Now, I’m a huge proponent of self-education and using today’s technology to our advantage—in fact, I think it sparks productive dialogue when information is brought into the doctor’s office—but as cliché as it sounds, I cannot emphasize enough the need for a professional diagnostic assessment. Trust me; the $15 copay is worth it.

Think of it this way: your doctor is your agency of record, but for some reason, you’ve decided to do your own brand website, aka diagnosis. We all know from AOR experience that your doctor is going to take one look at that diagnosis and say, “Damn, this is a mess; I wish they’d just paid me to do it.”

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Jul2

FDA Social Media Draft Guidance Released June 2014

fdaLeading up to its final guidance to be released in July 2014, the FDA has released draft guidance on how pharmaceutical companies and medical device manufacturers should interact with social media platforms with regard to fair balance and brand messaging. The first part of the recently released recommendations is focused on how companies post advertising and promotional messages to Internet and social media platforms with character space  limitations, such as Twitter and Google Sitelinks. The second part of the recommendations addresses how pharmaceutical and medical device companies may correct independent third-party misinformation about their brands online. While this guidance is recommended and not required, it will be beneficial for pharmaceutical companies to adopt the FDA recommendations going forward.

A brief review of the FDA recommendations is listed below, along with suggestions for practical implementation.

Internet and social media platforms with character space limitations

In its draft guidance Internet/Social Media Platforms with Character Space Limitations—Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices, the FDA outlines its recommendations for promotion of brand and product information using Twitter and other character-space-limited communications, such as Google Sitelinks. The recommendations are direct and seek to include fair balance in each individual communication.

The most salient points are as follows:

  • Reminder communications, which call attention to the name of a product but do not make claims, are exempt from this guidance
  • The full indication must be used when making claims in a communication
  • Benefit information should be accompanied by risk information within each individual communication
  • The content of risk information presented should, at a minimum, include the most serious risks associated with the product
  • A direct link to a more complete discussion of risk information about the product must be included in the communication

While a link to the ISI is adequate in such communications, the FDA further recommends that companies develop landing pages devoted exclusively to the communication of risk information about their products (e.g., www.product.com/risk). The format for the URL and landing page should clearly communicate that the destination will explain the risks associated with the product.

Many social media tools automatically use link shorteners to keep within the character space limitations of the communications. While the FDA does not directly oppose the use of shorteners, it recommends that the resulting URL denote to the user that the landing page contains risk information. (For example, prod.uct/risk clearly communicates that the destination is about risk.) Another solution to character space limitations is for the company to register shorter domain names that can then redirect to its product sites for use in social media.

One challenge that brands with black box warnings will face following this guidance, especially on Twitter, is in fully communicating risk information within a single tweet. For such brands it will be impossible to communicate all risks in the platform-restricted space; therefore, we recommend against using Twitter as a channel to communicate those products’ indications, benefits, and risks.

The FDA guidance also extends to paid search communications, such as Google Sitelinks. The Sitelinks feature displays up to 6 additional destination URLs for users to choose from when a paid search ad is displayed. In complying with the FDA’s draft guidance, most of the additional destination URLs provided by the brand would link to risk information in an attempt at fair balance, which might portray the product as riskier than it actually is. This might deter some companies from using Sitelinks to promote their products.

Correcting third-party misinformation

The second round of draft guidance from the FDA, Internet/Social Media Platforms: Correcting Independent Third-Party Misinformation About Prescription Drugs and Medical Devices, seeks to improve the quality of public health information by allowing companies to correct third-party misinformation that they find online about their products. Again, these are recommendations; it is not required that a company respond to such misinformation, regardless of whether it appears on a company’s own forum or on an independent third-party forum or website.

The FDA defines misinformation as positive or negative representations or implications about a company’s product by an independent third party. There are two types of misinformation: a misrepresentation of the label, which a brand will typically want to correct, and an exaggeration of outcomes, which a brand may be tempted to leave uncorrected. The FDA recommends that companies respond to both types of misinformation.

If a company decides to correct misinformation on a third-party site, it should:

  • Provide corrective information and a link to corrective information
  • Post corrective information alongside the misinformation or refer to the misinformation in its response
  • Limit the scope of the corrective information to be specific to the misinformation, and keep it non-promotional
  • Correct positive misinformation as well as negative misinformation
  • Keep records of corrective interactions

The FDA clearly states that it will not hold a company accountable for an independent third party’s subsequent actions or lack thereof after corrective information has been supplied. Further, companies do not have to continue to monitor the third-party site after information has been corrected.

Going forward

While it is not feasible for a company to monitor all third-party sites for misinformation about its products, creating Google alerts (or similar) will help ensure that it is notified when user-generated content (UGC) about its products is trending. A company can then respond appropriately if they desire. However, consideration must be given to the level of time and effort that legal and regulatory teams must spend reviewing and filing the corrections versus the impact smaller third-party sites and individual bloggers can have on public health information.

Alternately, a company can and should focus its attention to more prominent third-party sites, such as WebMD, Wikipedia, and brand-specific hubs, in their quest to correct misinformation. This will maximize the intention of correcting the message while appropriately weighting the effort.

Overall, the draft guidance marks a significant milestone in the pharmaceutical industry’s ability to keep pace with other industries in the social media space where consumers are increasingly seeking out health information. This guidance has been a long time coming, and now pharmaceutical companies can jump into social media knowing they will be FDA compliant when the final guidance is released.

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