Predictably, the pharma blogosphere is abuzz today with anticipation for the FDA public hearings set to kick off tomorrow.  The public hearing is being hailed in some circles as a shining moment that will herald in the dawn of a new era in pharmaceutical marketing.

Sorry to burst your bubble, but the FDA meeting to discuss social media as it applies to pharmaceutical companies will not singlehandedly change the face of marketing.  It is an important stepping stone for the industry that will surely drive increased attention to the need for social media policies and plans—but don’t expect a tidal wave of social media activity once guidance is issued.  We are more likely to see a ripple effect following these hearings and the resulting official FDA guidance.  And that is how it should be.

As I discussed recently in taking the safe route for social media, it is not in the best interest of any company to tackle the world of social media in one fell swoop.  Pharmaceutical companies have been reticent to engage in social media for multiple reasons—not just a lack of FDA guidance.  If the FDA was to issue clear guidance on how pharmaceutical companies are permitted to leverage social media it would lessen one of the many challenges facing the industry.

The FDA has the ability to ease some of the tension that surrounds social media for pharmaceutical companies by clearly outlining when fines will be levied and based on what parameters they will be doled out.  But hurdles will still exist.   In fact, if we are not careful, FDA guidance could have an adverse (pun intended) effect on the use of social media.  Because the industry has been so dormant in this area, it may be tempted to treat it like any other marketing discipline.  The FDA may very well facilitate this process by establishing an environment where pharma companies are forced to treat social media like advertising.  The impact of this would be incredibly detrimental and would only serve to build on the ill will that has befallen the industry.

I know this sounds like a pessimistic rant, but it is actually intended to be a realistic take on the public hearings.  I am excited about the fact that the FDA is finally holding a hearing on social media and the potential impact it will have on this industry.  It is an important step and one that will cause more than one pharma executive to stand up and take notice of the potential that social media holds.  Already there has been an uptick in awareness and meaningful conversations taking place on the topic.  These are the types of discussions that we need to continue to have in order to help solve not only the regulatory issues being addressed by the FDA, but other challenges as well. This is the immediate benefit of these hearings.

The lesson?  Social media requires a thought-out, strategic plan that takes into account various factors along the marketing spectrum.  One hearing by the FDA is not a silver bullet but it sure advances the conversation.

Adverse events.  Off-label usage.  FDA guidelines governing brand-specific communications.  These are the reasons often rattled off by pharmaceutical marketers for steering clear of social media.  But I wonder: are these really just convenient excuses?

I recently wrote two posts that explored this topic (Changing the Script for Pharma Social Media and Deflecting Myopia: Is Pharmaceutical Marketing Stuck in Neutral?).  The basic idea of both posts was that pharmaceutical marketers are either:

1. Inhibiting success by admitting failure before it occurs or;
2. Not even trying because, in their minds, it is not worth the effort.

Along the same lines, Sean Woodruff of the Impactiviti Blog wrote a post today on the Pitfalls of Doing Nothing.  His point (overly simplified here but I suggest you pop over and read the post in full) was that pharma companies think they are taking the safe route by staying out of social media, but in reality, the consequences of inaction could be significant.  With conversations happening at all times about your corporate brand, wouldn’t be advisable to add an informed voice to the mix?

The question still lingers then: is the regulatory environment surrounding the pharmaceutical industry a convenient excuse to shun social media efforts? A Recent study from Nielsen Buzz Metrics has shown that a scant 1 in every 500 online communications meets the criteria for AE reporting.  In addition, a survey conducted in April by John Mack of the Pharma Marketing Blog listed corporate culture as the primary obstacle to social media for pharmaceutical companies—not regulatory concerns.  The point here is not to dismiss regulatory issues as a non-issue as they should certainly come under close scrutiny before engaging in any form of social media activity.  The point is that in most cases, these regulatory issues are not deal breakers—they are deal influencers.

When you boil it all down, pharmaceutical companies are no different than other industries embarking on a social media journey.  Like consumer products and tech companies, pharma companies are scared of losing control of their brand more than they are of dealing with the regulatory environment.  Putting your corporate image in the hands of the general public is a scary thought that pharmaceutical marketers have not quite come to grips with in many instances.  But as Sean points out, that loss of control has already happened.  Consumers are already engaging in communities and shaping a company’s image.  Marketers should be under no illusion that they alone control the brand.

Pharma companies need to decide if they want to be a part of that community or forfeit all brand rights to the community at large.  If you ask me it’s an easy choice.

Today in Twitter land, there has been a bit of good-natured, virtual sparring from John Mack of the Pharma Marketing Blog and Rich Meyer of the World of DTC Marketing.  The debate surrounded the likely impact the upcoming FDA social media hearings will have on pharmaceutical marketing and whether or not the agency will issue any guidance.

John falls in the optimistic camp, boldly predicting that the FDA will have draft guidance by the end of 2010.  Rich on the other hand is skeptical that the FDA is little more than a spectacle.  As you can imagine, I hope that John wins the flip of the coin on this debate.

But what I found more interesting than the debate itself was some of the reasoning to uphold the argument.  Because in some ways, my head tells me that Rich is correct that the FDA hearings may not result in any quick action.  After all, the agency is the equivalent of a Boeing 747—quick adjustments are a complicated orchestration.  But my viewpoint is more of a commentary on the agency and its bureaucracy than the potential impact of social media for pharmaceutical marketers.  I have little doubt that social media holds immense potential for the industry.

Rich raises two areas of contention that I’d like to address.  The first is that “consumers are predisposed to distrust pharmaceutical companies and therefore don’t want to talk with them because they don’t want their personal data in cyberspace.”  He is absolutely correct that consumers generally distrust pharmaceutical companies.  The industry has built up a mountain of ill-will that needs to be overcome.  That is tough to dispute.  But similar to my previous post on a self-fulfilling prophecy, does that ill-will mean we should continue to ignore consumers?  Isn’t that the attitude that created this disdain in the first place?  If used ethically, transparently and with the needs of the patient in mind, social media provides an incredible opportunity to start mending the relationship between consumers and pharmaceutical companies.  Consumers do want to hear from drug companies so long as the information is not solely an effort to push product, is a conversation and not a podium and is informative.

The second point that raised an eyebrow for me was the assertion that “having an agency do your social media strategy is like having someone else speak for you at the dinner table.”  I believe the intent of this statement is that transparency is paramount when it comes to social media.  This is accurate.  Any interaction on a social network needs to be authentic and honest.  But an agency certainly has a place in this process.  Of course, I have a vested interest in this as I work for a PR agency but that’s not the sole reason behind my statement.  Sticking with a similar analogy, diving into social media without expert counsel (doesn’t have to be an agency) is akin to cooking a rack of lamb the first time without following a cookbook.  Or to offer an alternative analogy, it would be like facing charges in a court of law and deciding to serve as your own attorney.  It just is not prudent.

However, the role of an agency or any expert counsel should absolutely, positively, 100% NOT be to serve as the voice of the pharmaceutical company.  That part has to come from the company itself.  An agency can outline a strategy, point to relevant influencers, monitor social networks for relevant content, etc…Basically, an agency serves as the arms and legs that help deal with the scale issue presented by social media.

The upcoming FDA hearings will be an important turning point for social media in pharma.  Which way it turns remains to be seen.

The traditional model for pharmaceutical public relations is to focus on the product brand, not the corporate brand.  Healthcare consumers tend to identify more closely with product brand names rather than the company that controls that brand.

Case in point: how many average consumers do you think realize that Wyeth makes Advil, that Johnson and Johnson makes Motrin and that McNeil makes Sudafed?  I’d be willing to bet it’s well less than half.  Why?  A brand crisis in the past could have huge ramifications across the product portfolio of a pharma company.  The philosophy is similar to how firefighters attack a blaze—containment is key.

But that model is slowly but surely changing and pharma companies are showing a willingness to engage and invest more heavily in PR and social media that enhances the corporate brand.  Take a look at Johnson and Johnson as a prime example.  J&J is a highly decentralized corporation that controls hundreds of operating companies around the globe.  Because of this model, it would seem logical that the company would prefer brand PR over corporate PR.  But that’s not entirely the case.  J&J has been lauded for its foray into social media.  But a closer inspection of its efforts shows that they are aimed at enhancing the corporate brand—not a specific product brand.

And J&J is not alone. ePharmaRx recently posted a list of pharmaceutical companies that have established a presence on Twitter.  The list includes names like Bayer, Glaxo Smith Kline, Pfizer and Astra Zeneca to name a few.  Of course, the argument could be made that some of the aforementioned companies are not truly engaging at this stage of the game.  But hey, baby steps.

So why the shift to corporate branding efforts in the pharmaceutical industry?  It comes back to what Sally Suzman, Pfizer’s Chief Communications Officer, recently termed return on reputation.  It has become apparent to pharmaceutical companies across a broader spectrum that the corporate brand can create a halo effect that enhances the product brand.  If as a company you are viewed as compassionate, honest, responsive and accommodating to the consumer voice it will ultimately lead to product loyalty.

There is also the issue of regulatory concerns when it comes to social media for pharma companies.  The reporting of adverse events and FDA regulations are commonly seen as huge hurdles to social media focused on a brand.  But when you move to a corporate level, you have effectively mitigated some of those challenges.  That is not to say they go out the window entirely, but they are infinitely more manageable.

Brand PR and even social media will always be an important part of the pharmaceutical communications mix.  To think that corporate branding efforts will suddenly supplant brand-specific efforts is naïve.  However, the tide is clearly shifting, and pharmaceutical companies need to decide whether to go with it, or risk being washed away.

Please note: This post was also published on the SHIFT staff blog: http://shifters.wordpress.com/