A belated happy new year to all.
While we were away recharging our batteries to gear up for what is already an intense election season marked by increasing talk of drug pricing issues, we caught up on a few new developments regarding some drug marketing and promotion issues that we frequently address (in addition to managed markets issues). In particular, we came across some interesting material on Twitter that merited a closer look to see how brands have been utilizing that medium in the wake of FDA’s June 2014 release of its social media guidance regarding the presentation of risk and benefit information.
As many readers are undoubtedly aware, most brand manufacturers have shied away from utilizing Twitter for brand messaging. While there are many reasons underscoring that cautious approach, one of the principal hurdles expressed by manufacturers was an inability to convey textually relevant – and regulated – product information within the confines of Twitter’s 140 character limitation.
Twitter’s space constraints proved to be an insurmountable obstacle for marketers trying to squeeze product benefit and efficacy claims, along with significant risk information, to comply with FDA’s guidance:
Regardless of character space constraints that may be present on certain Internet/social media platforms, if a firm chooses to make a product benefit claim, the firm should also incorporate risk information within the same character-space-limited communication. The firm should also provide a mechanism to allow direct access to a more complete discussion of the risks associated with its product.
The prominence of risk information should be comparable to the benefit information within each individual character-space-limited communication, taking into consideration any formatting capabilities available on the specific Internet/social media platform.
If a firm concludes that adequate benefit and risk information, as well as other required information, cannot all be communicated within the same character-space-limited communication, then the firm should reconsider using that platform for the intended promotional message.
As a result, Twitter has remained a rather quiet corner of the pharma marketing world.
During our holiday reading, though, we came across a recent Twitter approach used by one manufacturer that may create a path forward for greater use of Twitter for branded messaging. To be sure, we do not have any insight into whether the tweet in question has led to more meaningful – or measurable – engagement with patients or health care providers, but we will be interested to see if other manufacturers adopt similar approaches for branded tweets.
The tweet we are describing is Janssen’s tweet for Xarelto, which came in early January 2016.
— JanssenUS (@JanssenUS) January 11, 2016
While some readers likely may be more interested in how an ad campaign involving Chris Bosh, Arnold Palmer, Kevin Nealon and Brian Vickers actually came together, we, of course, were focused more on the language of the tweet and the use of Twitter to convey messaging for a branded product.
In our view, what is most noticeable is that the tweet appears to avoid FDA’s social media guidelines entirely while at the same time making full use of Twitter’s character limitation and embedding a video into the tweet. Specifically, the tweet itself contains no information about the product’s benefits or efficacy (as would trigger certain requirements in FDA’s social media guidance), but instead alerts a Twitter user that a new product ad is available for viewing. The video itself is embedded in the tweet, ready for viewing, and links to a YouTube video that contains additional product information, including benefit and risk information. But because the tweet does not make an explicit product benefit claim, there appears to be no need to incorporate specific risk information within the same tweet, as required by FDA’s social media guidance.
Note too that even though no product claims are made, the content of the tweet is consistent with FDA guidance in that it highlights significant risk information for the product – the boxed warning in bold – and links to the package insert to convey the seriousness of particular risks. Obviously, a different scenario would be presented by a product with no boxed warning. And we think that this approach likely does not lend itself well to satisfying FDA’s other social media guidance regarding the correction of product-related misinformation by independent third parties (i.e., user generated content).
While it may be too soon for the manufacturer to measure the reach and/or pull through of this particular tweet, the structure of the tweet raises a number of interesting questions for all manufacturers to consider. First, assuming that these types of tweets are consistent with FDA’s guidelines, can manufacturers achieve the same messaging impact if they do not include product benefit claims within the tweet? Second, do tweets with embedded video content offer manufacturers a better path forward to regulatory compliance with FDA social media guidelines governing risk and benefit information, and should they begin looking at other potential ways to link to other DTC product content they control besides videos, like product websites, print ads or mobile app downloads? Finally, if manufacturers get comfortable with this approach, will they begin exploring greater use of other social media and publishing platforms like Facebook, Instagram and Pinterest? While we will continue to monitor use of these types of sites for product messaging, we are aware that one site not typically associated with customer or prescriber engagement – LinkedIn – recently has been mentioned as one social media platform that manufacturers and their senior officers are getting more accustomed to using.