The U.S. Food and Drug Administration (FDA) published a draft guidance in June of 2014 recognizing the challenges of reporting risks and benefits when marketing medical devices via social media, particularly media that limits the number of characters space allowed, such as Twitter.
The FDA maintains that this draft guidance includes non-binding recommendations, but recommendations nonetheless.
These are a few of the recommendations made for social media marketing of medical devices in the draft.
- Information regarding medical device benefits should be accurate and not at all misleading within each message.
- Each individual message about benefits should be accompanied by risk information within the same character-limited message or tweet.
- Risk information included with benefits in character and space limited platforms should include the most serious risks associated with the medical device – at minimum.
- Messages should use hyperlinks, or similar mechanisms, to allow readers to learn more about the risk information within the character and space limited message.
- If your organization believes that the character and space limitations of a messaging platform renders it impossible to provide appropriate benefit and risk information, your organization should consider other avenues for promotion instead.
- Prominence between risk and benefit information should be comparable within the body of the space constrained message.
The FDA goes even further, though, by recommending the use of formatting capabilities in order to highlight substantial risks such as using boxes for warnings and bolding words to draw the reader’s eyes to the risk information for the products and medical devices.
The bottom line about the guidance is that space limitations do not excuse you from following FDA regulations about marketing your medical devices. You still need to comply with the FDA whether you have 140 characters to make your message or 14,000.
Is there an Upside?
There is an abundant of good news in this. First, competitors are held to the same high standards. This means that no medical device competitor will have a leg up on social media and in text based ads. You’re all required to follow the law.
Second, savvy marketers understand that there are many ways to share the news about your medical devices to consumers without making claims – even making use of news reports on how ordinary people are helped as a result of the devices you market.
Finally, 140 characters is plenty to make great points. Just don’t limit all your messages to marketing.
Today’s marketplace includes building relationships instead of simply marketing products. Draft guidance may have been eagerly awaited, but the gist of it is that you still have to follow the current regulations and standards no matter how many characters are available to use.
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