As you’ve probably heard by now, The FDA has once again delayed its draft guidance on how pharmaceutical companies can use social media tools.  The groans can be heard echoing throughout the healthcare social media world.

After one delay at the end of 2010, the hope was that the FDA would be in position to at least tackle one of the many issues facing pharmaceutical companies engaging in social media.  However, when word spread yesterday that social media guidance was not quite ready, the general consensus was a feeling of dismay.  It shouldn’t be.

While FDA guidance is an important step to nudge the most hesitant pharmaceutical marketers off the sidelines, it is not an insurmountable hurdle.  Those that are expressing dismay over the latest setback probably had unreasonable expectations of what the FDA guidance will provide.  No draft guidance issued by the FDA is going to suddenly unleash a swarm of new companies into the social media community.  In fact, it’s not unreasonable to think that a pharmaceutical company’s ability to operate in a social media environment will get more restrictive—not less.  In addition, the guidance that does eventually come out from the FDA almost certainly won’t address specific channels as some hoped.  That’s a good thing.  We want this guidance to be flexible enough that it grows over time, allows for transparent engagement and ultimately leads to better patient outcomes.  Focusing on specific channels will not get us closer to that goal.

Even without social media guidance, there are plenty of strategies and tactics that are possible right now—with or without guidance.  Ultimately, when FDA guidance comes it will provide a clearer picture of where the boundaries are.  But the goal isn’t to push those boundaries—and if it is, you are doomed for social media failure.  As a company, if you are waiting for the FDA guidance as the spark to get your social media engagement started, you probably have some work to do first.  You need to commit to the conversation, understand the content gap that might exist and outline a clear strategy for your social media endeavor.

The FDA guidance will undoubtedly be an important step for the industry—but you needn’t wait to start your social media engagement.  The conversation is already happening—join in!

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