Will FDA guidance cause pharma to jump into social media head first?

The time for presentations and comments to the FDA on the use of social media by pharmaceutical companies has come and gone.  The FDA now has the not-so-enviable task of sifting through those comments and putting out some form of coherent social media guidance.

It’s a long road and nobody can accurately predict when that guidance will come.  Yet, hordes of people wait anxiously for the FDA to “rule” on the matter.  The pent up anticipation seems to indicate that with one wave of the wand the FDA will magically deem social media the pharmaceutical industry’s play pen.  The indication is that the FDA’s silence on the matter to this point is the only remaining hurdle to social media adoption by healthcare companies.  It is not.  Plenty of hurdles and landmines remain.

By issuing guidance, the FDA will not suddenly unleash a stampede of pharmaceutical companies that were waiting for the flood gates to open.  The participation of pharmaceutical companies will still be a slow trickle.  Why?

Number one: nobody is quite certain what the FDA will say on the matter.  It is quite possible that any guidance issued will be so limiting it will make social media engagement even more challenging that it already is today.  That possibility is slim though, as the FDA’s silence to date has acted as a repellant to any would-be social media efforts.

Number two: regulatory and legal hurdles will still exist.  You can bet that whatever guidance is issued by the FDA it will not encourage a free-for-all—nor should it.  This means that pharmaceutical companies will still have to operate within a controlled and sanctioned environment.  The practical implication of this is that the regulatory department inside pharmaceutical companies remains the biggest roadblocks to an engagement getting off the ground.  They will still harbor concerns and express a reluctance to move forward.  It is the job of the social media advocate/evangelist/expert/wingnut to understand those concerns.  The regulatory people should be folded into the process early and often.  Embrace them; don’t keep them at arm’s length.

Number three: I am still not convinced that the lack of FDA guidance is the biggest roadblock on the path to social media bliss for pharmaceutical companies.  Similar trajectories have unfolded in other industries (albeit, not regulated ones).  For example, B2B technology companies have been slow to adopt social media.  The reason is a mix of a corporate culture that has yet to embrace it and a lack of clear understanding of where the B2B audience is online.  This same dynamic holds true for pharmaceutical companies.  In order to move forward with social media engagement strategies, a significant shift in thinking is required.

This list could probably extend on for another 1,000 words and still not encompass the litany of challenges that exist.  The point of this is not to dash the optimism many feel about the FDA’s pending guidance.  I too am optimistic that this will help nudge some apprehensive companies off the sidelines.  Call me cynical (I prefer realistic or pragmatic): I simply don’t think the FDA’s guidance on social media will create explosive growth.  Instead, I think it will help to sustain the steady growth path already in progress.

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