Over the holidays, and without fanfare, the FDA issued Draft Guidance for Responding to Unsolicited Requests for Off-Label Information. The title of the guidance is a little deceptive in that within the document lies some draft guidance on dealing with social media in the form of ‘public’ platforms where some of this conversation may take place. The guidance doesn’t give us a road map for working with social media platforms such as Facebook and Twitter, but it is progress. The most noteworthy element is that unsolicited public inquiries for off-label information, as an example in YouTube comments for a pharma YouTube channel, should only get medical affairs contact information as a response.

The guidance came out while everyone was still digesting their Christmas dinner and it flew right under the radar of all the pharma Twitterati during the lull between Christmas and New Years. People returning to their offices in January found it in their inbox and panicked that the FDA has said something, anything, about social media. Digital agency leads scrambled to produce a POV on the guidance and the blogs began (email me if you want my POV).

There are now many, many interpretations and analyses out there, and Fabio Gratton did a great job of collecting them into a Storify stream listing all of the articles from media, agencies, pharma companies, and law firms. Another great tool was created by Jon Richman of Dose of Digital fame – this one is a flowchart for deciphering the sometimes tangled logic in the guideline. I love the sense of humor.

The FDA has some sharp people on their staff that clearly understand social media. The original request for response on social media (over two years ago, now) demonstrated a strong grasp of the issues. Therefore, it’s surprising that the FDA does not address moderation in the draft guidance. Moderation may be used to pre-review comments prior to public posting on platforms managed by companies.  It is possible using moderation tools to prohibit posting of off-label comments entirely and to respond to an inquiry privately without it ever being seen by the public.

We’ll see if 2012 is the year to finally see some guidelines.

Today Google announced it’s wallet, an electronic wallet located in your cell phone with tap-and-pay technology. With Google’s engineering prowess, it’s got to be a smooth customer experience – frictionless, as the saying goes.

Why so late? Doesn’t it seem like we should have been tapping and going at 7/11s and gas stations for a while now? The credit card companies have tried all sorts of experiments in Quick Service Restaurants and cabs for a while, but nothing seems to have caught on.

Google’s solution uses a near field communication chip to enable the magic, and requires companion hardware on the receiving end. Not every phone will have this technology for a while, but it does seem possible that someone would soon offer a standalone NFC wallet the size of a credit card. I’d sign up for that. Digital is infinitely scalable, so why not put your credit cards, frequent shopper cards, gym card, etc. on a digital wallet? At least it would leave you with a much smaller wallet with just your bills and drivers license, even if you were carrying an extra item.

It will be interesting to see whether this wakes up the bank associations like MasterCard…and American Express. Google does not know who they are dealing with. Those companies are fierce competitors and payment methods are their expertise. I worked on the transition from paper to paperless for gift cards and other instruments in the 1990s, and while these companies my not be first, they are fast followers and tenacious.

This story originally appeared in PRWeek Insider on 04/20/11 (subscription required).

More People are playing Farmville than Watching Dancing with the Stars. More people are playing Texas Hold’em Poker than are watching Glee.* And Zynga, maker of Farmville, has about half the monthly active users that Twitter does – 135MM versus 283MM.

Clearly, gaming is a big part of American life. People are choosing gaming for entertainment over all the other immersive options out there. As smartphones become even more ubiquitous, that puts a powerful gaming machine right in everyone’s pocket.

Gaming is not just for kids. 18-49 year olds make up the largest percentage of gamers at 49%, and the average age of the most frequent game purchaser is 40 years old. There are more people over 50 that play games (26%), than children under 18 (25%).*

Gaming for Healthcare?

Anyone who has observed their teenager in the death grip of level  10 of Angry Birds recognizes the complete concentration and immersion that experience offers. Could some of that focus and engagement be used for healthcare?

The Journal of the American Medical Association took a look at the impact of health gaming and found that: “Sufficiently engaging games might enhance the effectiveness of health messaging, allowing individuals to practice useful thought patterns and behaviors and encouraging them to explore and learn from failure in safe virtual environments.” JAMA reported that recent games had positive outcomes, such as Re-Mission, a game for adolescent and young adult patients with cancer, which improved adherence; and Wii Fit for obesity. Now, if that language sounds a little academic, consider the tone of most healthcare educational materials, which tend to be dry and impersonal.  Gaming can blend education and entertainment, so you can learn while having fun.

It comes back to your marketing objectives. Can you educate through a gaming experience? Can you motivate through a system of goals, feedback and competition? Could gaming be another way to tell the story and get the message across? If so, gaming could be an emerging avenue worth trying.

Gaming clearly has advantages on the social web for sharing of scores, competition, and team play.  From a news perspective, there are many angles, from the patient, to the disease, to the game itself. Gaming offers multimedia assets that can be used in news releases, YouTube, or Facebook.

What works for consumers, works as well with healthcare practitioners. What better way to teach a doctor about a new mechanism of action than an immersive and interactive game/learning experience? With the increasing use of tablets and other devices in detailing, the opportunities will only increase.

This story originally appeared in PRWeek Insider on 04/18/11 (subscription required).

Two weeks ago a Marc Jacobs intern publicly melted down on Twitter and then quit. Two weeks before that, Chrysler experienced some Twitter road rage, and an agency was fired. And two weeks before that, the Red Cross had to confiscate the keys from their tweeter for #gettngslizzerd.

Imagine if these accidents had happened in a healthcare setting? We don’t need FDA guidelines to understand the hot water we’d be in.

Pharma company Twitter feeds are heavily stage-managed. Posts are vetted by an army of regulatory and legal staff, and updates are timed like Obama’s inauguration. The few branded Twitter feeds are even more tightly controlled. But who tweets and how? It’s usually a junior staffer copying and pasting the approved post and frequently using their own choice of software. That’s the weak link. The examples at the beginning are a cautionary tale of people inadvertently mixing their personal and professional profiles, and of tweeters going off the rails.

Software Rx: Twitter feeds are frequently handled using a dashboard like Hootsuite which can manage a number of feeds at once and offers analytic capabilities for tracking tweets and mentions. It can handle Facebook pages as well, enabling you to easily syndicate content selectively across the social platforms. Even multiple clients can be set up. The lure is strong to add your personal accounts, and create a mothership dashboard so you can be complete master of your domain. Resist it, it’s a bad idea. It’s all too easy to click the wrong icon and post to the wrong account – especially late at night or in a busy airport. One wrong click and you blast your personal tweet about that new band to your client’s followers. Or, you might post that handbag website to your client’s Facebook page. Amusing, yes, but it’s not as funny the next morning.

The best practice is to create separate dashboards for work and personal accounts using different email addresses and logins. Then using themes, give them radically different colors and backgrounds so you can easily distinguish between them, no matter how flummoxed you might be. For added safety, consider using different browsers, like Chrome for work and Firefox for personal.

Mobile Rx: The same goes for mobile devices. For tweeting on the go, use a different mobile app for your clients and personal tweets. Put them on different pages or folders. Don’t tweet and drive.

Content Rx: If you’re tweeting for a pharma company or brand, your hands are already tied and the blinders are on, just carefully press ‘send,’ per the above. If you’re fortunate enough to be tweeting for a hospital or association in a less structured way, you need to have some guidelines for the voice of your feed. You are the spokesperson of the brand, and while you want personality and authenticity, behave as if your every tweet could be on the cover of USA Today, because if you screw up, it will be. Consider using a workflow where tweets are approved before they are issued.

So take your medicine and tweet me in the morning @markhdavis.

You have to be of  ‘a certain age’ or a classic rock fan to remember The Who’s song Going Mobile. But it’s very relevant today. Forester predicts that by 2012 more Internet access will occur throughout mobile devices than PCs. Sometime it seems it’s coming quicker than that. If you look around you on the train platform and see the folks nearby crouched like preying mantises over their mobile devices, it’s here today.

In the past few months there have been some excellent articles about the fragmentation of the web into various ‘walled gardens’ such as Facebook. One of my favorites is Forrester’s article and term, The Splinternet. Wired Magazine had a September cover article called The Web is Dead along the same theme.

So what’s a marketer to do? Get mobile fast. You don’t have to redo your whole website for mobile, just the essential pages a person would need on the go. And you don’t have to cover every mobile device, just the main ones your audience uses.

It turns out it’s not necessarily that difficult. A structured blog like this, running on WordPress, is a natural. For instance, WPTouch is a free WordPress plugin that shows a powerful, well-designed mobile theme version of your site to the most popular touch-based smartphones like the iPhone, Google Android phones,  and Blackberry. Over 90% of mobile web traffic originates from these devices. Pretty amazing, and it only takes minutes to set up. A paid version is only $39 and offers many more features. So, Goin’ Mobile may not be so hard – “keep me movin’,” like the song says.

Facebook introduced a service called Places last week in response to similar marketplace efforts like Foursquare and others. In a nutshell it allows you to share where you are and connect with friends nearby. The advantage to Places is the gigantic reach that Facebook has with a membership of over 500 million and its position as the social network of choice. That makes Places truly useful and a way to connect with your already established network (rather than creating a new one.) It also appears that Facebook is willing to partner somewhat with location based services on Yelp and others, rather than to wipe them out. Places currently works only on the Facebook  iPhone app and with other phones which support W3 geolocation.

However, Facebook still hasn’t learned from its privacy stumbles. The privacy default for Places allows you to check in your friends and tag them to a location without their permission. This can create alarm even in those digerati who are used to broadcasting their locations, as shown by a user’s experience in the New York Times this last weekend. Who wants to excuse themselves from a dinner date only to be ‘outed’ at a party down the block by Places? So, I recommend going in to your privacy settings in Facebook and disabling ‘allow others to check me in.’

This privacy issue is similar to others where Facebook has defaulted user updates to ‘public’ and has taken heat. They either won’t learn and/or truly see this as the way social networking is evolving. In spite of this I believe Places will soon be a leading geolocation service – purely due to Facebook’s size.

Today, the IgniteBLOG reported the first ever branded pharma tweet. The tweet came from twitter.com/racewithinsulin. Of course, I found out about  in on Twitter.

This development is interesting from a couple of perspectives. The twitter feed is from a brand advocate, rather than a company. The twitter homepage includes both Levemir and Novolog important safety information and logos as part of the page background, making it almost like a brand.com website. Ignite did a very nice writeup on the effort in a previous blog post, so I won’t repeat the analysis.

The tweet itself – apparently the 12th tweet made – includes both the full product name (brand name and generic), and a link to the prescribing information. My knee jerk response was to say this was out of step with the recent FDA crackdown and the new rules for paid search. But it’s not. There’s no indication anywhere (I had thought diabetes was in the twitter username – obviously now I see that it’s not). The link is even to the PI, rather than a brand or unbranded website. If you were weird enough to view it on the Twitter homepage for the account you would get the whole story. It’s like wearing belt and suspenders – they’re covered a couple of ways. To my mind they could have linked directly to the brand.com.

So congratulations to breaking some new ground to the team at Novo Nordisk! Weaving an occasional promo tweet into the stream from this brand advocate seems palatable enough from the point of view of one of his follows. “And now for a message from our sponsors.” Of course, they’ll have to watch the ratio of promotion to hard news, but that seems a reasonable trade-off.

Social Media Landscape

Were any of you on Facebook this week? If not, your kids probably were, and you’ll be there shortly. The fastest growing segment of the Facebook population is 35 plus years of age. That means that our core demographic target as a company is moving into online social media very fast.

Social Media is an approach to online communications that shares most or all of these traits:

• Participation
• Openness
• Conversation
• Community
• Connectedness

It’s an individual searching for connection with someone just “like me.” And people take the advice of a person that they trust as seriously or more seriously than a doctor’s advice.

Sure, it makes headlines, but is this just a flash in the pan? Hardly. Sit back while we work through a few facts. Facebook has over 80 million unique users, just about the size of Germany. English Wikipedia has over 800,000 articles and is larger than the Encyclopedia Britannica and Microsoft Encarta combined. YouTube served over 3.6 billion video streams last month. There are 26MM US blog writers, and 60MM US blog readers. All of the proceeding figure are growing at a rate of 25-40% a year.

What is happening with the online population at large applies very specifically to healthcare information seeking. There are 63MM US adults who use “Health 2.0″ content and services online, meaning health blogs, forums, videos, patient support groups, etc.

Working in pharma, we know our business is different than most. We are not selling Skittles. We have safety, regulatory and legal concerns that make it difficult to engage in a two-way dialog. We are most comfortable in a one-way dialog, where we do all the talking. We are working within a box. But that’s the challenge to our creativity  -  how we can be influential within the box we’re stuck in.

Let’s take a look at some of the leading Social Media channels and how they have been used in our industry.

There are over 113 million blogs worldwide. About 45% of online consumers read blogs, about the same percentage as those that use social networking sites. With blogs anyone can publish their own online diary – the trick is getting someone to read it. Many succeed at this challenge. The online newspaper/blog the www.huffingtonpost.com had 6 million visits just last month, about one-third the traffic to www.nytimes.com. When consumers are looking for health information online, many find blogs and take value from the personal stories there. Blogs such as www.sixuntilme.com (Diabetes), www.hepcboy.com (HepC), and www.addadhdblog.com (ADD & ADHD) are hugely influential in their categories..

Online social networking sites are communities of people who share common interests and enjoy similar activities. The names Facebook and LinkedIn are part of the everyday elevator chatter you now hear on campus. Pharmaceutical products are cautiously working their way into this space. Gardasil, the cervical cancer vaccine from Merck, won raves for its TV advertising. They are equally skilled online – just search ‘cervical cancer’ on Facebook and you’ll come to an area where you can learn more, share your story on the “wall,” or become an “HPV Ambassador.”

If you looked at YouTube as if it were a search engine, it would now be the second largest behind Google! You can easily search on YouTube for any of a variety of conditions: Diabetes, ADHD, Asthma, etc. and you’ll be surprised at the number of results you’ll find.  Try “Mechanism of Action,” and you’ll see our own Gleevec leading the pack. 80% of online consumers view video each year.

Blogs, Social Networking and YouTube are only the most visible tactics. There’s also Twitter, Wikis, Social Bookmarking, Virtual Reality, and new options coming every day.

So what is Novartis doing in this area? According to a recent tally by Basel, there are 56 past, ongoing or planned projects in Social Media. There are Zometa and Femara Facebook pages. There are clinical trials for Diabetes on YouTube. Oncology recently launched a site to connect all the Chronic Myelogenous Leukemia (CML) patients all over the world.

It’s important to realize that Social Media should not live in a bubble; it’s most effective when part of an integrated marketing strategy. Social Media strategy begins with objectives and the correct tactics will follow.

Don’t have a big budget for Social Media Monitoring? There are many available free tools that are high-quality and offer interesting insights. The following list contains both Best-in-Class solutions for monitoring as well as specialty tools for specific purposes. If you know of one you feel should have made this list, use the comments section at the bottom of the post, and I’ll keep this updated.

Monitoring the Blogosphere / User Generated Content
Mainstream media lags substantially the buzz in the Blogosphere. Many people turn to blogs for news first, particularly in areas where experts offer specific insights or are ‘untainted’ by profit motives. You can track you own company, brands, and issues, using the following services. You can also easily track your competitor’s companies, brands, and issues.

Technorati One the best known and for good reasons. Comprehensive and with custom RSS feeds that let you get quick updates on any blog that mentions your company name.

Blog Pulse (Buzzmetrics) The free version of Buzzmetrics from Neilsen Online. It has very interesting trend and conversation tracking tools.

Google Blog Search If a tree falls in the blog forest, it’s likely that it will be found by Google Blog Search. Even if the blog isn’t in Google news, or doesn’t show in a Google search, Google Blog Search might still find that obscure story about that competitor’s launch. You can set up auto-alerts that will be delivered via email or RSS.

Trendpedia has a simple interface and seems to be well-regarded.

Icerocket was recently singled out to me by some Social Media pros as strong. It has tabs at the top to easily limit your search to Blogs, Twitter, MySpace, etc.

Boardtracker Forums and message boards can host some of the most important conversations about your company and brands. How can you find them? Use this.

Google Alerts makes it very simple to keep track of the latest buzz via email. Google Alerts let you track web, blogs, news and groups for any phrase you want. You can select to receive emails daily, weekly, or “as it happens.”

YouTube If you think of YouTube as a search engine it would now be #2 in search! Video is the preferred learning method of many people. Maybe your company or brand is there?

Facebook Lexicon Facebook has become so big, it’s time to pay attention to the conversations that happen there. All you need is a Facebook account to search any keyword and instantly see how often it is discussed on Facebook user’s “walls.”

Twitter
Twitter is an animal unto itself with an avid following. You can peer into the cyclone of posts by using one of the following tools. These are just a few of the many, Twitter seems to stoke creative software solutions.

Twitter Search is Twitter’s native search engine. Just type in what you’re looking for.

Tweet Scan searches Twitter, identi.ca and other Laconica-based sites with more being added all the time. You can search public messages and user profiles with results available via email, RSS, JSON, and Twhirl.

Twit Scoop shows what’s hot on Twitter right now in a ‘cloud’ format. It has interesting search and graphing capability.

Other Interesting Discovery Tools
Blogs and message boards are just part of the ‘long tail’ of the UGC web.

Digg surfaces the best stuff as voted on by their users. People collectively determine the value of content. You can use the search box to see if you rank.

Stubleupon helps you “stumble” around the Web and find new content. You tell the service about your professional interests or your hobbies, and it serves up sites to match them.

That’s the short list of Best-in-Class solutions. It should be enough to keep you up all night searching. If you feel I’ve missed a key solutions, use the comments section at the bottom of the post, and I’ll update the list.

Later Additions:

Here’s a huge master list – How-To: Search the Social Web – Ultimate Toolkit

A big list for Twitter specifically: 9 Twitter Search Apps : Better Than Twitter & Google

Tired of emailing your friends, then calling, then emailing again, then wondering who’s going to show up for your soccer, football, or tennis game? Try Nike Playmaker. Interesting way to enable something online that’s always a pain to do – and extend the Nike brand.