Considering the Future of Pharmaceutical Promotions in Social Media Comment on "Trouble Spots in Online Direct-to-Consumer Prescription Drug Promotion: A Content Analysis of FDA Warning Letters".

Francesca Renee Dillman Carpentier

doi:10.15171/ijhpm.2016.15

Abstract

This commentary explores the implications of increased social media marketing by drug manufacturers, based on findings in Hyosun Kim's article of the major themes in recent Food and Drug Administration (FDA) warning letters and notices of violation regarding online direct-to-consumer promotions of pharmaceuticals. Kim's rigorous analysis of FDA letters over a 10-year span highlights a relative abundance of regulatory action toward marketer-controlled websites and sponsored advertisements, compared to branded and unbranded social media messaging. However, social media marketing efforts are increasing, as is FDA attention to these efforts. This commentary explores recent developments and continuing challenges in the FDA's attempts to provide guidance and define pharmaceutical company accountability in marketer-controlled and -uncontrolled claims disseminated through social media.

Highlights

Consumers who actively seek out online health information tend to believe the information to be credible, irrespective of whether a medical expert has authored the information.[14]
Unlike their perceptions of other methods of direct-toconsumer advertisements (DTCA), consumers are less skeptical of online information unless they are expressly motivated to recognize the intent of these messages as persuasive.[15]
The message might be originating from a compensated blogger or brand ambassador, as was the case with celebrity Kim Kardashian’s paid endorsement of morning sickness drug, Diclegis, disseminated via Instagram post.[17]