compass hc fda presentation 11.12.09

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Compass Healthcare Communications Social Media Recommendations November 12, 2009

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Compass Healthcare Communications Presentation to the FDA on Social Media.

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Page 1: Compass Hc Fda Presentation 11.12.09

Compass Healthcare Communications

Social Media RecommendationsNovember 12, 2009

Page 2: Compass Hc Fda Presentation 11.12.09

Growth of Internet & Social Media

• More patients look online for health information (102.3 million patients looked for prescription drug information alone; doubling over the last four years).1

• According to Manhattan Research, more than one-third of patients now use social media for medical information.2

• Additionally, healthcare professionals are spending more time online. A recent survey demonstrated that physicians spend an average of eight hours a week online for professional reasons, and four out of every five physicians will use a smartphone by 2012.3

1. Manhattan Research. Press Release, “Study: 102.3 Million Patients Online for Prescription Drug Information, Doubled in Past Four Years.” 1 October 2009. Available at http://www.manhattanresearch.com/newsroom/Press_Releases/consumers-patients-online-health-pharma-2009.aspx.2. Manhattan Research. Press Release, “Health 2.0 on the Rise – 35% of U.S. Adults Use Social Media for Medical Information.” 7 October 2009. Available at: http://www.manhattanresearch.com/newsroom/Press_Releases/health-2.0-social-media-on-the-rise.aspx.3. Manhattan Research. Press Release, “Physician Smartphone Adoption Rate to Reach 81% in 2012.” 5 October 2009. Available at: http://www.manhattanresearch.com/newsroom/Press_Releases/physician-smartphones-2012.aspx.

Page 3: Compass Hc Fda Presentation 11.12.09

Types of Social Media

• Wikis Wikipedia, Medpedia

• Social Networks Facebook, MySpace

• Video and Photo Aggregators YouTube, Flickr

• Blog platforms Blogger, Tumblr

• Microblogging Twitter

• Niche Networks Daily Strength, Inspire, advocacy

communities

• Social Bookmarking Digg, Reddit

Translates into thousands of conversations taking place every day; regardless of industry involvement

Wikis

Social Networks Vide

o & P

hoto

Aggr

egat

ors

Blog Platforms

Microb

loggin

g

Nich

e Netw

orks

Social Bookmarking

Page 4: Compass Hc Fda Presentation 11.12.09

Defining Social Media & Its Value

• Defining social media Not static Owned by parties

with different interests

• Focus should remain on holding industry responsible for its own communications

Page 5: Compass Hc Fda Presentation 11.12.09

Question 2

• Follow the spirit of the DTC guidelines, which have been translated for traditional interactive work since 1996

• For channels that do not allow for balance copy (due to space or other limitations): Post an unbranded message with a link to the product website

that features fair balance, or, Post a branded comment without key claims or indication

information (consistent with reminder ad guidelines) and feature a link to the product website/fair balance o This approach would not apply to black box drugs

How can manufacturers, packers or distributors fulfill regulatory requirements (i.e., fair balance, disclosure of  indication and risk information, postmarketing submission requirements) in their Internet and social media promotion, particularly when using tools that are associated with space limitations and tools that allow for real-time communications (e.g., microblogs, mobile technology)?

Page 6: Compass Hc Fda Presentation 11.12.09

Question 2

• If communications are re-posted or re-tweeted by others removing fair balance or links, the company should not be liable Accept that with best intent, materials that meet regulatory

requirements will evolve in the social media realm

• Unique consideration should be given for the posting of non-promotional information related to corporate access and reimbursement programs

How can manufacturers, packers or distributors fulfill regulatory requirements (i.e., fair balance, disclosure of  indication and risk information, postmarketing submission requirements) in their Internet and social media promotion, particularly when using tools that are associated with space limitations and tools that allow for real-time communications (e.g., microblogs, mobile technology)?

Page 7: Compass Hc Fda Presentation 11.12.09

• Dissemination is similar; outlets have increased exponentially

• Acknowledge control of information is transferred in both traditional marketing and social media

Transmission of Information

Page 8: Compass Hc Fda Presentation 11.12.09

Question 3

• Demonstrate effort to correct information Self-identified company representative Include link to PI, copy should not be promotional in

nature

• Understand best intent by not requiring companies to correct information Not all outlets will accept corrected information Unjustly burden companies engaging in social media

• Engage responsibly and realistically

What parameters should apply to the posting of corrective information on Web sites controlled by third parties?

Page 9: Compass Hc Fda Presentation 11.12.09

Health Literacy

• Social media helps industry better reach patients and caregivers Research insights to better

address their language, needs and concerns

Provide educational materials and accurate information where patients are already seeking it

Improve health literacy and easy transmission of reliable information

Page 10: Compass Hc Fda Presentation 11.12.09

Contribution of Social Media

• Better, more accurate patient and caregiver-directed information In places where they are

already seeking information

• Increased health literacy

Improving dialogue

and outcomes

Page 11: Compass Hc Fda Presentation 11.12.09

Thank you