The following analysis was written by Justin Freid, Director Search Engine Marketing, CMI/Compas: The FDA has proclaimed it is acceptable to promote a product on company controlled forums and channels. It is also acceptable for a company to promote their products on third party sites such as Twitter and Facebook. Per the FDA‘s a firm is responsible for product promotional communications on sites that are owned, controlled, created, influenced, or operated by, or on behalf of, the firm.’
For ‘open’ networks such as public Twitter profiles and Facebook pages, the first submission will need to provide deep detail into how users can engage with the channel. This will include submission of creative, screenshots and explanations of how users can interact with the channel. On an ongoing monthly basis, companies will need to provide the FDA with a list of the social networks they are active on and the date of their most recent activity. For content and promotions on closed or private channels, companies will be required to submit screen shots of any and all activity. Examples of this would be a protected Twitter account or groups on Facebook or LinkedIn that are not open to the public. It is important to note that this not only covers profiles and blogs created to represent the company but also employees and their profiles who speak on behalf of the company.
Health care professionals are active on social media, with many HCPs utilizing LinkedIn and Twitter as channels for thought leadership and peer to peer interaction. Through native advertising (tweets, status updates, sharing of articles) and paid advertising on these social networks, pharmaceutical companies can interact with HCPs in a completely new forum. While there still exists a grey area surrounding the FDA’s stance on native advertising of pharmaceutical products, paid advertising options such as display and text ads on social sites are proving to be extremely effective.
Good News for Marketers
While the guidelines will not lead to every brand and parent company to begin flooding Twitter, Facebook and other social media sites with status updates and advertisements, we now understand what the FDA holds companies and the firms working on their behalf responsible for and can constructively work with that information.
We also have an understanding that a screenshot and submission will not need to occur each time a user replies to a tweet or status update. Instead, marketers will need to keep the FDA up to date with what networks they continue to utilize on a monthly basis.
Paid Advertisements vs. Interactive Promotional Media
The FDA’s definition of Interactive Promotional Media lends itself very well to what digital marketers categorize as ‘native’ advertising. From sponsored branded content to Facebook status updates the FDA submission/review process for these types of advertising is different from some of the paid advertising options available on popular social networks. For example, display ads on Facebook and LinkedIn do not ‘interact’ or ‘engage’ users in real time conversations. So technically, they should fall under more traditional digital marketing guidelines. But other paid social media advertising options like Sponsored Tweets enable users to reply/retweet and respond with user generated content. Sponsored Tweets, though paid, would fit better under ‘Interactive Promotional Media.’
People can request a PDF of the POV on our website at http://www.cmimedia.com/insights/cmi-whitepapers.