Social technologies in the medical technology industry
Medical device and pharmaceutical vendors in the regulated health care industry are feverishly trying to develop Web 2.0 strategies that leverage social technologies to connect with patients and health care providers. However, progress has been slow, in large part due to the FDA’s existing regulations on product labeling and the lack of clear guidance on how existing regulations from traditional print and television media apply to the newer, internet-enabled Web 2.0 channel.
My use of the term “social technologies” is a conscious choice over the ubiquitous “social media”. The latter connotes a communications strategy aimed at pushing out a message, as the marketing function has traditionally done through newspapers, magazines, and television. The tools that enable social interaction on the internet are capable of offering companies much more than an outbound marketing channel. When used effectively, Web 2.0 enables individuals to come together as a community. I posit that Web 2.0 has flourished in settings where individual users perceive a direct benefit from their engagement, and where they feel empowered and free to interact. Companies that can create the right environment for their customers will reap much more benefit than can be achieved from “just another outbound marketing channel”; these companies will be able to harness their communities’ collective wisdom for driving innovation processes and rely on customer-to-customer interaction for word of mouth marketing and for solving simple service requests.
One of the key, fundamental differences between the old and new channels is directionality. Print and television are largely unidirectional, allowing vendors to disseminate a carefully crafted message that complies with FDA regulations. The internet made it easier for customers and vendors to engage in instant dialogues, which can still be controlled and made to comply with regulations on labeling. On the other hand, Web 2.0 social technologies bring together groups of people so that they can interact with one another. These tools benefit from network externalities, but as the number of engaged users grows, the resulting multilogues become harder, if not impossible, to control. Further complicating matters are tools like Google’s SideWiki, which allows a user to visit any site and to leave comments in the margins of the web page. The comments are stored on Google’s servers and are adjoined to the site’s web page only in the users’ web browser. The website owners have no control over the comments that visitors leave in the SideWiki [1] but a naïve third party may go to the company’s website, stumble upon the SideWiki discussion, and think that the company is somehow involved. Legal and regulatory teams fear that a visitor may discuss an unapproved application of their medical device, and that the FDA will hold the company responsible for off-label promotion. Unfortunately, the FDA has not provided guidance and companies can’t control and don’t have the resources to respond to every SideWiki comment on every page that may be left on their websites.
[1] Last month, Google announced a webmaster SideWiki entry which allows the owner of the website to write a special SideWiki entry that will remain the top entry of that page. This may be exactly what the FDA regulated industry ordered; companies will now be able to leave a disclaimer distancing themselves from the rest of the user generated notes in the margins.
