Part 2
Social Media: What’s Not to Like?
Welcome to the second post reflecting on the 23rd Annual Pharmaceutical and Medical Device Ethics and Compliance Congress. In each post, I review some of the key topics covered during the conference and provide my reactions, as well as related tips and suggestions for maximizing the effectiveness of your compliance training curriculum.
This time around I delve into the ever popular (and somewhat confusing) topic of social media and, in particular, the session titled, MINI SUMMIT 5: Social Media — Auditing and Monitoring to Promote Compliance in this Rapidly Evolving Landscape.
If you attended the conference and missed this session, it’s worth the time to watch it online. And don’t be fooled by the title, the discussion wasn’t limited to auditing and monitoring. Training was mentioned early and often. Here are some of the key ideas shared during the session:
Follow the FDA (and the FTC)
The tone of the presentation, as well as the industry’s attitude towards social media, was best summarized with this quote from one speaker, “In some respects social media is heavily regulated, and … it’s the wild, wild west.” The rules and regulations are evolving and still somewhat undefined, but the risks continue to grow.
The presenters emphasized that the FDA’s regulations related to product promotion also apply to social media (staying on-label, not making unsubstantiated claims, avoiding promotional claims without risk information, etc.). The FTC has also issued a series of guidance documents on social media. Subsequently, the social media ground rules and principles established by both agencies need to be incorporated into your curriculum. Employing a continuous learning approach, with reinforcement solutions and performance tools blended into your plan, is the most effective way to ensure your team remembers and applies those rules and principles.
For example, you could deploy a foundational training module that covers your social media policy and then later follow up with a scenario-based microlearning module that specifically focuses on the proper way to respond when encountering product misinformation online. In terms of performance support, intranet banners and strategically placed posters are also a great way to consistently reinforce important tips and reminders.
Influencing the Influencers
The FTC’s guidance documents also cover the increasing use of social media influencers. According to the presenters, the FTC is particularly focused on “establishing a connection between the advertising and the influencer.” The agency has even established a preferred list of hashtags to help influencers identify themselves as paid spokespersons (#sponsored, #ad, #paid).
What does it mean for your social media training? You need to consider external as well as internal audiences, including any potential influencers involved in the promotion of your products on platforms such as Twitter and Instagram. Who is training your influencers? How often do they receive training? What form of training do they receive? How is it being tracked? You’ll sleep better if you have deployed on-going training that emphasizes compliant behavior to those in a position to influence the promotion of your products.
The Same Rules Apply to MSLs, Executives, and Outside Agencies, Too
The presenters often cited the distinction between promotional social media posts and those related to corporate communications. Each type follows a different set of rules. This difference does not depend on one’s job role, but rather the nature of the post itself. Whether an individual is part of the medical team, the C-suite, or even with an outside agency, that does not give them carte blanche to post content without regard to the rules.
Once again, it is important to evaluate your training audiences inside and outside your organization. What are the risks? Do the same risks apply across the board? Should all topics be covered at the same frequency? Are you making any risky assumptions based on job titles? Such audience/risk analysis is the starting point for effective social media training and a compliance training curriculum in general.
The More Examples, the Better
One of the more interesting comments in the session centered on the potential risks of training itself. One presenter said, “We did so much training, it actually scared the staff.” She continued by saying the training they deployed was generic in nature and lacked the specificity and examples necessary to make it stick. In her company’s case, they made the training more effective by adding examples of what employees can and can’t like or share. That’s an excellent idea that could be further enhanced by examining the training deployment calendar.
For instance, you could create a “training series” in which the foundational training establishes the “what” and “why” of your social media policy, and follow-up with microlearning, games, mini assessments and other learning nuggets that focus on specific social media examples. When training is spaced across a learner’s timeline, learning has been scientifically proven to increase and the retention of those examples will grow.
In addition, workshops and training games offer more opportunities to reinforce the good and bad of social media activity. When deployed live or virtually, the sessions foster a dialogue in which examples can be discussed and participants can cite their own examples of what they have seen online.
Summary
At the start of this mini summit, presenters referred to a quote by the former director of the Office of Prescription Drug Promotion, Tom Abrams, “It’s the message and not the medium, so we expect the same regulations to apply to social media…” Platforms will change and evolve, but the messages your learners post, like, or share need to adhere to the good foundational compliance practices the government, HCPs, and patients expect.
Thanks for reading! If you’d like to see examples of foundational or reinforcement training solutions to address the risks of tricky subjects such as social media, contact us at info@pharmacertify.com to speak to one of our compliance training specialists.
Sean Murphy
Product and Marketing Manager
PharmaCertify