Looking Back on My 2015 New Year's Resolutions for Pharma

Before I publish my recommendations for 2016, let me review my 2015 New Year's Resolutions for pharma to see how many were actually achieved.

2015 Resolution #1: Forget about using Twitter to promote brand name drugs to consumers.

I don't know if pharma marketers have forgotten about doing branded tweets, but I haven't come across any nor have I heard many laments about how hard it is to overcome FDA's social media regulatory hurdles.

But there was one failed attempt to bypass the FDA via a promotional post on Instagram. Of course that was a post on Instagram by Kim Kardashian promoting Diclegis.

Before the Instagram ink was even dry the FDA sent a Warning Letter to Duchesnay, the drug’s maker. That letter put the kibosh on the “one-click rule”:

“We note the statement, ‘[F]ind out more www.diclegis.com; www.DiclegisImportantSafetyInfo.com[,]’ appears at the end of the social media post; however, this does not mitigate the misleading omission of risk information. By omitting the risks associated with DICLEGIS, the social media post misleadingly fails to provide material information about the consequences that may result from the use of the drug and suggests that it is safer than has been demonstrated.”

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