Last week, my #hcsmeu co-founder and collaborator Silja Chouquet offered a great summary of some of the reasons why those who take an interest in health care in Europe must guard against modeling their own activities in 2010 along the lines of those that were undertaken at the FDA social media hearings in Washington last month.
I won’t repeat the post’s observations and conclusions here, but if you have yet to read it, please do so now. Silja, myself, and the Health Care Social Media Europe community will have a lot more to say about this in the months to come.
Instead, I will conjour up a symbolic pachyderm that may like nothing better than to settle itself in Europe’s parlour by asking a question that was not raised in Washington, namely: is it appropriate that pharma should be allowed to use direct to consumer (DTC) messaging within social media environments at all?
Regardless of whether they facilitate ‘1 click away’ access to fair balance and safety information, ‘improve’ patient safety through the use of a mooted adverse event reporting widget, or create a collaborative framework for patient interaction, from one perspective the FDA hearings were little more than an attempt to legitimate DTC advertising within social media environments without having debated whether they should be allowed to do so in the first place.
There is a fallacy of intention at the heart of the proposition that pharma marketers have a de facto right to conduct themselves within global social media environments in the same manner that they have traditionally done within broadcast media in the USA, and that the outcome of the FDA hearings must of necessity be viewed as a means of discerning how, rather than why, regional DTC marketing should be undertaken within the flourishing global patient and consumer communities that have been brought together by social media.
Would a ‘1 click’ rule help patients make better health decisions, or would it provide the pharma industry with better targeted advertising opportunities?
Would an adverse event reporting widget improve safety for patients, or would it reduce the risk of litigation for pharma?
Would a collaborative framework enhance intra-patient and/or patient-health care professional interaction, or would it afford pharma the opportunity to inveigle itself into a conversation it is danger of being shut out of?
The European pharmaceutical industry would probably also like to pass immediately into an arena wherein interminable discussions will be held as how it could conduct its marketing activities within social media without having first scrutinized whether it should be allowed to do so as a first principle. In order to prevent this conceptual segue taking place, I would favour coaxing our elephant from the parlour to the portico: from the space within which the debate is being held, to the entrance that it would symbolically block. At least we would then be able to have a discussion as to whether it should be allowed in through the front door rather than being shooed in through the back way.
Whilst there are any number of justifiable conversations and sanctionable interactions that the pharma industry could rightfully expect to be able to productively engage in within social media, DTC advertising is not one of them.
To my mind, DTC advertising has no place in European (and therefore by the necessity of extension, global) social media. It is critical that the global – not just American – patient communities who have been largely excluded from the debate until this point should be making their voices heard in this regard by contributing to the commentary that the FDA is currently collating, as well participating in the survey that John Mack is running.