1.)    The thwack of several notebooks hitting the conference table in united frustration,

2.)    A collective grumble from the people around the table, or;

3.)    Nervous laughter.

Rarely is the idea of working with the regulatory and compliance group greeted with a round of applause and viewed as an easy task.   This has always baffled me.  The goal of your RC team is not to put up insurmountable roadblocks to getting a social media program off the ground.  Dealing with RC should not be akin to a root canal.  Their goal is to help you.  More importantly, their goal is to protect you.

Here is the thing about social media people—they are creative types that like to push the boundaries.  That’s all well and good, but a little dose of reality is always welcome (remember the yin and yang of social media?).  Left to their own devices, many social media marketers will run afoul of regulatory boundaries—either from recklessness or ignorance.  Neither excuse is acceptable.

The good social media marketers among us understand that a reckless approach to social media is not a successful one.   The best social media marketers realize that RC is not trying to block social media engagement—they are the only avenue to making it happen.  Think of the RC team as a catalyst to social media engagement.  Next time you are sitting around the table discussing an idea, make sure RC is present from the outset for early input.  This will make for an easier approval process, ensure RC is part of the idea-generation phase and allow for a more cohesive team.

RC is not your biggest roadblock to social media engagement—in fact, they might be your biggest ally.

Just like my wife is the yin to my yang, pharmaceutical social media programs need to find a balance (you knew there had to be a segue right?).

Like a scientist trying to prove an established hypothesis, a pharmaceutical marketer can make the case for just about any social media strategy if they look long enough.  Before conducting any type of online listening or social media research, a marketer could have already decided that Facebook is the perfect platform.  With this decision already made, the process of finding supporting research is a selective exercise.  The research that supports the conclusion is pulled to the front and the rest is simply glossed over.

It’s reasonable to walk into pharmaceutical social media planning with a hypothesis.  The danger arises when you are unwilling to change your conclusion based on the research at hand.  Social media demands an open mind.  The way people interact, the functions of community and the social currency are all unique.  A social media marketer needs to research, listen and observe and allow that to shape strategy—not the other way around.

On the flip side, there can be a tendency to get so lost in the research and data that you never emerge with a conclusion.  You can spend months rehashing the same information without forming a cohesive strategy.  While a willingness to follow research is important, decisiveness is equally important.  It’s that whole yin and yang thing again—you need balance.

Online listening is a critical step to developing a social media strategy.  It helps to inform the strategies and tactics that will best serve your audience.  Use the information gleaned from social media listening to build a social media strategy that ties directly to the patient need.  But don’t use the mountains of information as a crutch.  Don’t use it as an excuse to continue stalling engagement.

Be thoughtful.  Be flexible.  But be decisive.

It is this balancing act that contributes to some of the difficulties in getting pharmaceutical social media programs off the ground.  Many companies lack a solid grasp of exactly what their risk quotient is when it comes to social media.  And to complicate matters, a successful social media strategy needs to incorporate stakeholders from several functional areas including: legal, regulatory, safety, IT, marketing and PR.  It’s likely that your legal team is going to have a different tolerance for risk than your marketing team.

You can see the obvious source of conflict here—when you get a bunch of people around the table with different priorities, reaching an action plan is a challenge.  It’s okay to have competing interests at the table.  In fact, it’s encouraged.  However, the problem lies in the fact that people rarely acknowledge when competing interests are present.  Instead, meetings get derailed by the inevitable stalemate when each functional area fights relentlessly for their own cause.

Here’s a better idea: clear the roadblocks immediately.  Start off the meeting by having an honest discussing about risk tolerance.  Ask everyone in the group to provide their input on how much risk they are willing to take in social media.  Here are some questions to ask:

• Are you open to publishing unbranded content? How about branded?
• Are you open to allowing comments on company-run social media properties?
• Would you be comfortable with responding directly to patients in public forums?
• Are you prepared to handle an adverse event through social media?

It is impossible to eliminate risk when engaging in social media.  But to ignore that it exists during the planning process is a treacherous path.  Establish your risk quotient from the outset and lay out a plan for mitigating and dealing with that risk.

See where I am going with this?  In their infancy, pharma social media marketers needed a bit of a “Rage Against the Machine” mentality.  Marketing best practices said nothing about direct engagement with the patient, letting go of brand control and moving away from mass audiences to more targeted engagement.  The very premise of social media marketing ran counter to many established marketing norms—it bucked “the establishment.”

Here’s the catch though: You know what happened to Rage Against the Machine?  They broke up despite their overwhelming success.  The band broke up because the decision-making process had fallen apart and they felt like they were straying too far from their original intention (this is where the comparison falls apart a bit, but you get the point!).

How does social media marketing as a discipline avoid the same fate as Rage Against the Machine?  Stop working against the machine.  Social media marketers have always proudly displayed a cavalier attitude—believing they were changing the way companies marketed and interacted.  But cavalier attitudes are not always the best way to enact change.

At a pharmaceutical company, there is a very methodical process that needs to occur long before social media engagement is ever reached.  Want to engage with patients on forums?  Better check the FDA guidelines on that one and write a new company policy for engagement?  Think you might see a few adverse events?  You need to write a new policy on how to handle adverse events reported through social media channels.  Have aspirations of responding to comments on Facebook and through Twitter?  You better devise a response plan for each medium and consider who has the approval power to maintain a consistent flow of communication.

Authentic engagement is always a laudable goal in social media.  But you can’t focus on just engagement when working with pharmaceutical companies.  You should be adept at writing social media policy, running training sessions, understanding AE reporting protocols and running robust listening programs.  These are the building blocks of social media success and they fall right in line with what pharma companies have always done.  Will you swim with or against the current?

Embarking on an online listening project solely as a means to create a full-scale engagement strategy is an adequate approach.  But as I’ve touched on time and time again here, when we put social media in a vacuum we run the risk of becoming irrelevant.  So where else can the intelligence of social listening support brand marketing efforts?  Extending that even further, where can social listening break outside of the marketing department and provide value across the brand?

It doesn’t take a huge leap of faith to see obvious opportunities for social media listening to help inform marketing efforts beyond just creating an engagement strategy.  Despite this, social media listening as a mechanism to augment market research is overlooked.  When you are dealing with large pharmaceutical brands there is likely a dedicated market research team.  If you are not careful, social media listening can feel like a competitive threat to their function and role inside the brand.  Of course, it’s not a threat and as social media marketers we should work hand-in-hand to determine what market research needs from us and how we can augment their process—not supplant it.  Through your online listening, you might find that people talk about the symptoms associated with a brand differently than you imagined.  The conversation online might in fact be more colloquial than clinical.  This type of simple intelligence can have big implications for your brand marketing strategy.

This is just one simple, easy example of extending social media listening beyond serving as a bridge to engagement.  Social media is a strategic function of an organization’s engagement strategy.  However, marketers too often think about social media in a silo.  Market research is an easy connection point to demonstrate and extend the value of social media beyond just engagement.

Many, including myself, did our best to quell those fears.  There are essentially two lines of reasoning when calming the nerves of the safety department at a pharmaceutical company:

1.)    People don’t want to report AEs using social media channels. There is a line of reasoning that says most people would prefer to follow traditional channels to report an AE and not take to the public forums of social media.  The idea is that there won’t be an influx in AE reporting because that’s not the intent or spirit of social media.

2.)    The other and more commonly used line of reasoning is that the data shows that the 4 criteria that constitute a reportable adverse event are rarely met online.

Folks like BuzzMetrics and Jonathan Richman have done phenomenal work to illustrate the validity of this point.  The fact is; reportable AEs are rare in social media channels.  It’s a compelling storyline: increased conversation does not have a direct correlation to increased adverse events.

Again, the data bears this out.  However, it doesn’t fully reflect the reality of the pharma landscape.  Recent conversations I’ve had have hammered home a point that has long been apparent.  For the safety departments at pharmaceutical companies, the fears of adverse event reporting were never about “reportable” AEs, they were about acknowledging the realities of their job function.  That reality means the safety department has to handle all possible AEs that come in through social media channels, not just the ones that are reportable.  This is where the overwhelming burden starts to become tough to manage.  As the engagement goes up, so does the frequencies of “possible” AEs.

Any social media engagement for a pharmaceutical company necessitates a policy change on handling adverse events and almost certainly increases the burden on the safety department.   This doesn’t mean you should shy away from social media entirely, but it does mean you need to acknowledge the task at hand for the folks in your safety department and work with them to enact effective policy change that mitigates the burden on any one department.  Chances are a good number of the current operating procedures for adverse event reporting can be replicated for social media channels.  Start by evaluating the current protocol and then fill in the gaps on the missing pieces for social media.

The good news is that more conversations (and even “possible” AEs) means more data.  Contrary to popular opinion, most healthcare companies want to know when their product does not work as intended.  Instead of trying to convince companies that the AE reporting burden doesn’t exist, let’s shift our attention to figuring out how to mitigate that burden most effectively.

What happens when social media policy changes on a dime?

One of the unspoken occupational hazards of social media is the fact that many of our strategies are contingent upon the whims of the platforms and communities we operate within. What happens when one of the social media platforms changes the game?

For a pharmaceutical company engaging in social media, a slight shift could require drastic changes in social media strategy. It’s no secret that Facebook, Twitter and other social media platforms have demonstrated a propensity to change policies on a dime. Decisions that Facebook makes on privacy settings or changes Twitter makes to who has access to the firehouse can cause panic amongst the pharmaceutical companies operating within those communities.

People seem to forget that companies such as Facebook and Twitter are businesses too.  If a policy change is going to provide more data for advertisers or attract more page views, they are going to do it without blinking an eye.  It’s all in the name of profit.

So where does that leave the pharmaceutical industry that has sought to exact some measure of control in social media? Where does it leave a cautious industry that has designed a whole strategy aimed at staying compliant with current regulations?  If a social network can change its tune at any moment—how does a tepid industry stay prepared?

Plan better.

At a recent conference I attended I listened to a session on global implementation of a pharmaceutical social media marketing program. The session addressed the challenges of dealing with different regulations across country boundaries. The point of view shared was that you should find the most restrictive regulations and use that as your benchmark—ensuring you are in compliance in less rigid regulatory environments. In the case of the social media platform that can change its guidelines at any moment, the opposite is true. Plan for the current environment, but have a contingency plan for what you will do if the game changes. Don’t be forced into reacting to changes, address them before they even arise. Plan for the moment when social media becomes entirely community and conversation driven with no pre-moderation options.

What is your contingency plan if a conservative approach to social media is no longer an option?  There will certainly be naysayers inside the organization that will want to peel back social media engagement as a result of looser restrictions on social media platforms.  Be prepared to convince them that pulling out of these communities is the wrong decision.  Demonstrate that you have planned for this scenario and have a plan in place to step up your monitoring capabilities, fit an AE-reporting framework into the existing escalation procedures of the company and prove the benefit to continued involvement.

Changes on social media platforms will continue to occur—whether to existing sites or emerging.  Don’t be caught off guard.

Along that path, the individual has very different needs that can guide the content creation of a pharmaceutical company engaging in social media.  Understanding those information gaps along the patient pathway is critical to healthcare social media success.  A person is more apt to trust the company that’s been there from the start rather than the company that showed up only in the patient’s time of need.  Social media relationships should be built to last and not transactional in nature.

But you understand this already.  The more pressing question is: what is it that people want along the patient pathway?  To begin to form an answer to that question, it’s helpful to understand the changing information consumption habits of today’s patient:

• 23% of individuals with a chronic disease go online for the purpose of finding others with similar health concerns
• 17% of cell phone users have used their phone to look up health and medical information
• 78% of home broadband users look online for health information
• 60% of people classify themselves as visual learners
• 67% of specialist physicians own smart phones and 75% of those doctors use their smart phone to view medical apps like Epocrates

All of this leads to an important point: social media strategy requires a robust content syndication network. Most content creation efforts focus on text-based efforts.   But all data around consumption habits points to the need for a mix of text-based content along with video, audio, Slidehare and interactive games.  And we are not just creating content for the oft-repeated “three screens”—we need to think about four screens (TV, computer, smartphone and tablet).

The patient pathway should map to the patient engagement span.  There is no single approach to achieve this goal.  By starting off with a listening program to understand the patient population and their needs along the patient pathway, you can begin to offer the right types of content at the right time.  Content creation in social media channels needs to evolve from text-based and at a single point-in-time (usually treatment or diagnosis) to multi-format, multi-device and at every point along the patient pathway.

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!

This is a commonly used method for describing the value proposition of social media.  By focusing on the lost opportunity of intercepting and shaping conversations, social media professionals hope to convince skeptical marketers that it’s time to engage.

By ignoring conversations happening online, a brand is absolutely missing out on an opportunity to connect with patients, offer engaging content and pinpoint an information gap.  Of course, there are two sides to the same coin and focusing on the lost opportunity is not always the best way to convert skeptics into believers.  It is worthwhile to think beyond the lost opportunity and consider the fact that you may lose your brand entirely.  That’s a whole lot more than an opportunity squandered (talk about scare tactic).

Here is the choice facing marketers: shape or be shaped by the conversation.  Social media enthusiasts would interject here with the tired cliché, “you can longer control your brand, the people control your brand!”  For the most part, I agree, but if there’s zero semblance of control, why are we spinning our wheels talking about strategy setting, issues management and authentic engagement?  A social media strategy is not close your eyes, plug your ears and see what happens.

By engaging, you are shaping the conversation and shaping the brand.  The very ACT of engagement is a brand attribute.  Social media engagement is not about control in terms of precise messages, but you are able to gain some control over your public image.  For a pharmaceutical company, social media allows the brand to commit to hearing feedback, to show its dedication to health, to demonstrate its ability to respond to patient issues and to show a human-side of a company in an industry that deals with deeply personal issues.  Sounds like worthwhile brand attributes huh?

If you choose to ignore reality, you will not only lose a patient, your brand image will be tarnished and perhaps irreparably damaged.   What will you do, shape or be shaped?