On September 29, the U.S. Food and Drug Administration (FDA) extended its comment period for 30 days on two draft social media guidances: one focused on how manufacturers and distributors of drugs and medical devices use social media to present risk and benefit information about prescription drugs and medical devices, and one on how manufacturers and distributors of drugs and medical devices may use social media to correct independent third-party misinformation about their prescription drugs and medical devices.
The FDA’s interest in this matter stems from its responsibility to oversee the labeling of drugs and medical devices. The U.S. Supreme Court defines “labeling” broadly in a way that counts character-constrained social media content created by manufacturers and distributors of drugs and medical devices as “promotional labeling.”
In the guidance on using social media to present risk and benefit information, there is concern that social media platforms with character space limitations pose a challenge to the feasibility of balancing the presentation of benefits and risks associated with drugs and devices in the communication. In the guidance on using social media to correct misinformation, the FDA is concerned with content created by manufacturers or distributors of drugs or medical devices in response to unaffiliated, third-party user-generated content about drugs and medical devices on social media which may contain misinformation about a drug or medical device.
In general, the emergence of social media as a communication platform begs the questions of what content is best suited for deployment via social media, and to what audiences, and when? Indeed, even within SBM, as we’ve grown our social media presence these questions arise: What information is best suited for delivery to our membership via social media? For example, it wouldn’t make sense to push critical information about annual meeting deadlines to the membership only via our Twitter account—such information requires more content than can be contained in a Tweet, and we know we don’t reach the majority of our members with social media. Our YouTube-based Video Contests, on the other hand, have strategically leveraged social media by appealing to those in our membership who are already comfortable with a technology-mediated platform and who are interested in sharing brief synopses of their research with a broader audience.
I doubt these questions about the most appropriate use of social media will be settled anytime soon, and since SBM counts many researchers and practitioners with health communication expertise among its ranks, we think you all likely have something important to say on the matter! We hope you’ll read the draft guidances and take advantage of another month to share your thoughts with the FDA. And we hope you’ll share your thoughts with your SBM colleagues, too—either via our related LinkedIn discussion, or even perhaps a character-space-limited tweet! You can also answer a one-question poll and view the results.