Thank you for stopping by to leave a comment.

The point you raise is absolutely germane to the consideration of this issue from a global perspective, namely: to what are we referring to when we talk of ‘DTC’?

All three of the definitions you offer could be said to pertain.

If you want specifics within the EU, you have to refer to the codes of practice for the promotion of medicine for the country in question. Links are collated on the EFPIA site:

http://www.efpia.eu/Content/Default.asp?PageID=296

That’s only the black and white, however; there are innumerable shades of grey.

Where, for example, does this post on the UK ABPI’s site sit along this spectrum? (see the paragraph entitled ‘the Informed Patient Initiative’). Is it a guideline? Is it a comment?

http://www.abpi.org.uk/publications/publication_details/expert_patient/power_point_otherInfo.asp

Then there’s the Danish journalist who probably thought his blogging in no way, shape or form resembled DTC advertising. Unfortunately for him, the Danish judicial system thought it did:

http://www.burrillreport.com/article-1381.html

What can we conclude from the above?

I think we have to begin by conceding that ‘DTC’ means something different just about everywhere. To me, it is conclusive evidence that the EU can’t just look to America for the FDA’s forthcoming guidance when it comes to consider its own stance(s). It has to make up its own mind(s).

I have seen that it’s defined quite differently both in different countries and among people in the same company. To one, it might mean directly advertising a specific brand to a patient. To another, it might mean setting up a non-product-specific community. To a third, it might mean ANY communication with a patient, branded or unbranded.

It’s a critical distinction, as people take sides on your very thought-provoking question. I’ll reserve my answer until I hear yours, so I can ensure I’m answering the right question.

Thanks,
JMR

Thanks for your comment. With new times come new tools. With new tools come new expectations. It is not a given that DTC advertising has a right to exist within social media in the USA, regardless of how it is regulated.

Social media creates conversation, builds trust, and facilitates interaction. It’s a relational space, not a transactional one. Pharma should look at the ways in which it can use social media to rebuild its shattered reputation rather than attempt to influence sales.

Long-term advocacy is going to achieve a lot more than short-term sales campaigns. You can’t do both. In social media, there’s one shouldn’t even attempt if you want to be taken seriously.