How to market drugs and devices on social media?
Promoting drugs and medical devices on social media in a highly-regulated industry may seem like a daunting task with the abundance of social media platforms and the unique qualities associated with each one. For example, a drug promotion strategy optimized for Facebook might not meet regulatory compliance for Twitter, Instagram, Google, or Snapchat due to character space limitation. It is necessary to take note of the differences between these platforms and adjust accordingly to ensure compliance with FDA guidelines.
General overview of a regulatory-compliant product promotion on social media
At the top of the landing page, the firm will communicate brand and established names together with the dosage form and quantitative information together.
If the firm is making a benefit claim about the product in the post, they need to provide information on risks and allow access to a more complete discussion of risks associated with the product (i.e. a link to the product website) all in the same post.
See below for a comprehensive Twitter example.
How to communicate benefits of a drug using social media?
The 3 main points to keep in mind when communicating benefit information of a product through social media:
- Benefit information should be accurate, non-misleading, and contain material facts
- Benefit information should be accompanied by risk information
- If adequate benefit and risk information cannot be communicated given character restraints, the firm should consider using a different platform for promotion
How to communicate risks of a drug using social media?
The 4 main points to keep in mind when communicating risk information of a product through social media:
- Risk information should be presented together with benefit information
- The content of risk information should, at minimum, include the most serious risks associated with the product
- A hyperlink should be provided to allow direct access to information on all associated risks
- Prominence of risk information should be comparable to benefit information
Comprehensive Twitter example:
Landing page (top):
Xdrug (hyp hydrocholoride) 200mg capsules
Note: In this example, Xdrug (hyp hydrochloride) is the FDA approved name
Xdrug (hyp HCl) for mild to moderate hypertension. May cause minor headaches and nausea in patients with arrhythmia www.xdrug.com/risks (139/140).
Please keep in mind that if you are considering promotion of a prescription drug using an ad extension, the requirements will change accordingly.
What if we want to include other product information?
FDA states that they do not object to the following:
- Communicating established name directly to the right of or below proprietary name
- Substituting commonly recognized words for symbols (i.e. Hydrochloride for HCl)
- Using punctuation marks to help with information presentation
- Denoting a chemical ingredient with scientific abbreviation
For further information, FDA’s social media draft guidance and webinar Q&A can be found here.