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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2015 New Year's Resolutions for Pharma Marketers

My #1 New Year's Resolution is the same every year: 

Stop telling pharmaceutical marketers what to do all the time.

Unfortunately, I have never kept that resolution. So, here's my list of 2015 resolutions for pharma marketers:

1. Forget about using Twitter to promote brand name drugs to consumers.

Although most pharma marketers know that it is impossible to "fit a square peg in a round hole," they still want to believe it is possible to "fit" all the FDA-required important safety information in a branded Rx tweet as long as they can convince the FDA to sanction the "one-click rule."

Granted, in the past the FDA has itself used this rule in its own tweets about Rx drugs. But it no longer does that and PhRMA's argument that "what's good for the goose is also good for the gander" (see "Drug Industry Rips Into FDA Over Social Media Guidelines") just won't sway the Agency, IMHO. So let's just call the whole thing off and get on with using Twitter for more meaningful dialogues with stakeholders; e.g., tweet chats (see "OMG! AstraZeneca Hosts Twitter Chat & World Does NOT End!" and "How to Host a Successful Pharma TweetChat").

I have a few more.

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