360DigitalInfluence

The much anticipated FDA hearings on how pharma and medical device companies should be able to use the Internet and social media for promotion kicked off today and the presentation room at the NTSB was packed with formally dressed people with expectant faces, ready to participate in what most people consider one of the most important moments in the history of online advertising and promotion in the medical space.

Based on the presentations this morning (including mine on behalf of Ogilvy) there were several themes that emerged as topics that will be interesting to track throughout the rest of the hearings and beyond. To a large degree, these were also the points that the FDA asked probing questions on after speakers were done presenting, which is an indication of what topics the agency considers to be most important as well. The speakers in the morning session included Ogilvy PR, Pew Prescription Project, Eli Lilly, PhRMA, Pharma Marketing News, IAB, VuMedi, WebMD and WEGO. Based on listening to those presentations, here are a few topline thoughts on implications and common themes that are emerging so far:

1. Good quality content for patients and HCPs from companies IS worthwhile and desired. Through the morning proceedings, everyone agreed that companies should have SOME ability to create and promote content online. This is an important agreement moving forward, as it assumes that the focus on future guidelines from the FDA will be about HOW companies can interact online and not on the broader question of IF they should even be allowed to. If there is one big conclusion that I hope the FDA takes away from today, it is that there is an important and meaningful place for pharma and medical device brands to share content and messages online, and this category of information should not be silenced completely or banned.

2. Doing nothing is not an option. A few speakers mentioned the same point this morning, that with the growing number of “unscrupulous” sources of medical information online from people such as “snake-oil salesman” promoting miracle cures, the necessity for the FDA to step forward and help to define what acceptable forms of marketing online are is vital.

3. Companies should not be responsible for policing the Internet. One of the most common questions that companies are asking is how deep they should need to go when it comes to finding and correcting bad information. While opinions on that point may vary, several people this morning mentioned the same point of view that companies should not have to police the entire Internet for bad information.

For the rest of today, you can watch the rest of the proceedings live at http://www.capitolconnection.net/capcon/fda/111209/FDAlive.htm.  Also, if you would like to read more about our POV that we presented today, including a summary of our “3 C’s” model for accountability, you can visit the following resources:

Ogilvy’s Presentations Today and Tomorrow at the FDA >>
Summary of Ogilvy’s 3 C’s Model For Accountability >>