Wednesday, October 7, 2009

On Your Mark. Get Set. Get Set. Get Set…

While the real fun won’t begin until the FDA holds its public hearings on digital and social media guidelines November 12 and 13, you can almost feel the mix of apprehension and hope coming from pharmaceutical companies and agencies, alike.

At Extrovertic, we lean more towards the hope side.

Much like a dog that depends on his invisible fence collar to give him an audible warning beep before shocking the hell out of him, the pharmaceutical industry will ultimately find comfort in having clearly defined boundaries within which it can safely operate.

My partner Dorothy Wetzel likes to remind people that before the original DTC guidelines were established in 1997, it was perfectly legal for pharmaceutical companies to advertise on television. But they didn't, out of fear that they wouldn't handle the risk/side effect information to the FDA's liking, creating a messy and costly situation for themselves.

Unfortunately, the process will take some time. Comment letters will continue to be accepted through February 2010, after which it will take up to a year to publish draft guidelines, accept more comments from the public, and then publish final guidelines. This means it probably won’t be until 2011 the FDA sets its new rules in place. But it will be well worth the wait.

"The guidelines will provide some clarity around what pharmaceutical companies can and cannot do," says Dorothy. "Everyone is being cautious right now."

What companies should do in the meantime, is use this time productively. They should start building some simple pilot programs into their marketing mix, so they’ll have a healthy head start on those still waiting for the guidelines.

By limiting these programs to small markets and simple tactics, they can mitigate the risk yet reap the rewards of success. Not to mention all the learning garnered along the way.

They should also start educating – and yes, socializing – everyone within the company about social media. Suggest that everyone from the mailroom to the C-suite get familiar with Facebook, Twitter, Youtube, Flickr and blogging. Have them open their own accounts if they can.

While some may look to the guidelines negatively, as interfering with their business, those who think ahead will see it as a great opportunity and look to maximize its potential as soon as today.

– Mark

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