An American think tank representing some of the biggest pharmaceutical and health companies in the United States has issued guidance for the use of social media and online forums in the industry. The group, known as the Digital Health Coalition (DHC), has produced a list of seven guiding principles in an effort at self-regulation. This follows the failure of the authorities to issue any definitive principles for online activity.
The health and pharmaceutical industry has always been aware that dispensing online health advice and drug information is a highly sensitive area, yet it is also something for which there is considerable public demand. The industry was hopeful that a lead in this field would be taken by the US Food and Drug Administration (FDA); however with the exception of some direction of how to deal with off-label information requests, the FDA has not expanded on the industry’s use of the internet.
The DHC has openly stated that the proposed principles are not intended to replace any official regulations regarding the industry’s use of online media, but hope that they will provide a focus and stimulate informed debate on the subject.
A full copy of the principles as released by the DHC is given below:
Social Media and User-generated Health and Medical Content: Guiding Principles and Best Practices for Companies and Users
1) Regulated healthcare companies should endeavour to participate in social media as a means to promote public health, improve patient outcomes and facilitate productive patient/physician relationships.
2) Regulated healthcare companies are not responsible for online user-generated content that they do not control. Regulated healthcare companies are deemed to “control” health and medical content if (i) it owns such health and medical content and has material editorial authority or (ii) it paid for the creation of such content and has material editorial authority over such content.
3) Regulated healthcare companies have a responsibility to report adverse events they become aware of. Regulated healthcare companies should follow the existing adverse event reporting rules in place at the FDA.
4) Employees of regulated healthcare companies should disclose their material company relationship when posting comments/content or engaging in an online conversation relating to a company product or relevant healthcare issue.
5) Regulated healthcare companies should endeavour to respond to questions on sites they control within a reasonable period of time, and to implement reasonable measures to enable timely responses to crisis and emergency situations.
6) Regulated healthcare companies should endeavour to make reasonable efforts to correct misinformation that is factually incorrect.
7) Regulated healthcare companies should endeavour to appoint employee(s) tasked with the role of “patient liaison” focused on representing the best interests of the patient online.