This One Goes to 11

  • by: |
  • 11/22/2011

By now it should be clear to regulated healthcare communicators that delaying robust entry into the world of social media due to lack of FDA guidance is an empty excuse. And, as more and more people turn to social media as their first and primary portal for healthcare information, absence from the playing field isn’t only a bad business decision – it’s irresponsible.

Regulated healthcare industry must participate in social media –not because of its potency as a marketing vehicle – but because it’s the right thing to do.  That being said, here are 11 principles that must serve as the basic substrate of regulated social media participation.  (Why eleven?  Because, in the immortal words of Spinal Tap’s lead guitarist, Nigel Tufnel, “It’s one louder.”)

1.     We engage in social media to help improve the lives of patients and advance the public health of our nation.

2.     We will thoughtfully engage in social media while remaining in compliance with both the letter and the spirit of FDA regulations.

3.     Our social media engagements will have both strong public health themes and appropriate marketing communications.

4.     All social media messages and partnerships must be accurate, appropriate and transparent.

5.     We believe that social media presents multiple opportunities to learn more about how our products impact the lives of patients.

6.     We believe that social media engagement allows us to correct errors and misperceptions about both our company and our products.

7.     We believe in using social media discover adverse drug experiences, which will then be addressed off-line.

8.     We will strive to interact in a timely manner, appropriate to the general expectations of social media.

9.     We believe that social media must be regularly monitored and our programs measured in real time to gauge effectiveness.

10.  We respect but are not responsible for user-generated content that resides on sites we do not control.

11.  We believe the path to engagement is through useful and thoughtful content and commentary.

One principle that runs as a red thread throughout all of these 11 principles is transparency.  Real, honest transparency – not the usual translucency that “in compliance” often brings.

It’s time for action.  As Friedrich Engels said, “An ounce of action is worth a ton of theory.


Center for Medicine in the Public Interest is a nonprofit, non-partisan organization promoting innovative solutions that advance medical progress, reduce health disparities, extend life and make health care more affordable, preventive and patient-centered. CMPI also provides the public, policymakers and the media a reliable source of independent scientific analysis on issues ranging from personalized medicine, food and drug safety, health care reform and comparative effectiveness.

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