As someone deeply immersed in pharma communications, and especially the newer realm of social networking, I’ve been closely following the ongoing process of the industry/FDA dance, trying to figure out how social media/web 2.0 approaches “fit” with pharmaceutical manufacturers and their various audiences.
And I keep wondering if we’re going about the whole thing the wrong way.
Think about the fine print PI (Product Information) you see in a magazine, accompanying a prescription drug ad. How many people do you think really read that? And, of that miniscule number, how many actually understand it?
This is not “communication.” It is “exposure of comprehensive required information.”
Now stop and think. If the joint goal of patients, doctors, regulators, and manufacturers is the right treatment given to the right patient at the right time for the right reason, then what we need is more than mere CYA disclosure. We need communication, designed properly for each audience, and digestible in ways that reflect how we genuinely communicate.
I’m in the process of selling and buying a house. And, roughly, there’s a 3-fold communication/thought process:
- 1. Basic, initial go-or-no-go information that helps me figure out whether something might be for me (e.g., a 2-bedroom split-level with a flooding basement on a 0.2 acre lot near a highway is not of interest).
- 2. A deeper layer of information that will let me whittle down further what matters, based on key points (e.g., a house visit with the realtor to really explore the place after all basic stuff has narrowed things down).
- 3. All the inspection and contractual details that must be waded through (comprehensive disclosure) once we have a pretty good idea of direction (e.g., call the lawyers and examine the paperwork).
We don’t start with #3. But much of what passes for pharma communications is so hog-tied by regulatory pressure on the comprehensive disclosure front, that the cart is effectively placed before the horse — if the horse is even allowed to show up. Effective communication is severely hampered.
If we’ve done full disclosure, such that the FDA isn’t dropping big fines, yet we’re really not communicating effectively with about the right treatment for the right patient at the right time for the right reason, then I have to conclude that we’ve all failed. And that’s what I fear will happen with the proposed FDA guidance on social media in pharma – we’ll all be so tied up with the disclosure minefield that no one is paying attention to the real point – what does it mean to effectively communicate on every level about prescription drugs and health?
There are basic principles of instructional design and “layered” multi-channel communication that seem to me far more vital than an endless “cover your backside” fear-based pursuit of comprehensive disclosure. I’d far rather see time and creativity invested in designing a prescription drug product information portal with layers of information (digestible for all audiences), multimedia education, and controlled interactivity than figuring out how we’re going to stuff a full PI into a coffee mug, a magazine insert, a TV ad, or a tweet. Can’t we take advantage of all this linked and multi-channel approaches to communicate more effectively and completely, rather than less so?
Social media provides wonderful new ways to establish information-sharing and build bridges with stakeholders across the entire healthcare chain, from drug manufacturers all the way through to patients. But if we look at it through all the old lenses, I suspect we’ll end up with the same old communication constipation that we have now. That would be a shame.
Steve Woodruff is Founder and President of Impactiviti.
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