FDA: No Unsubstantiated Claims, Even on Social Media

No Unsubstantiated Claims on social mediaIn case some wondered, FDA guidelines apply on social media as well and liking a post from one of your followers promoting unsubstantiated claims is an endorsement of those claims.

In December 2012, the FDA sent a warning letter to Amarc Enterprises regarding two websites. This letter has garnered attention because it references Facebook. The FDA details a variety of serious concerns over the way Amarc is marketing their vitamins, in particular their websites have numerous testimonials that are unsupported by clinical data.

For example, “PolyMVA helped save my life. I began a regimen of PolyMVA… After 3 months, the Stage 2 cancer was down to Stage 1.” These vitamins have not been approved by the FDA and are being improperly marketed as drugs. Similar claims were made for pets using the products and the FDA notes that this is also a violation.

Here is what the warning letter says about Facebook: “We also note claims made on your Facebook account accessible at: https://www.facebook.com/poly.mva, which includes a link to your website at www.polymva.com. The following are examples of the claims: In a March 10, 2011 post which was ‘liked’ by ‘Poly Mva’:

  • ‘PolyMVA has done wonders for me. I take it intravenously 2x a week and it has helped me tremendously. It enabled me to keep cancer at bay without the use of chemo and radiation… Thank you AMARC’”

The product’s Facebook page has been taken down, but it appears that the claim was posted to the wall. Not only was the claim left on the wall, it was “liked” by the page administrator which would be a clear endorsement of the claim. The letter also mentions a blog post on the Amarc site that makes claims that are unsupported by scientific data.

Interestingly, their other Facebook page is still live and posting things like this: “THE BINDING OF PALLADIUM, A RARE TRACE MINERAL, WITH ALPHA LIPOIC ACID, A POWERFUL ANTIOXIDANT, DRAMATICALLY INCREASES NUTRIENT ABSORPTION AT THE CELLULAR LEVEL AND THROUGHOUT THE BODY – A BREAKTHROUGH THAT DISTINGUISHES POLY-MVA® FROM ANY OTHER SUPPLEMENT!”

I posted a link to the FDA warning letter on their wall and asked for a response. They replied, “Discussions with the FDA are ongoing and the issues raised are being addressed. AMARC is committed to our products and working with health agencies in complying with any applicable rules and regulations. This is somewhat of a normal review in the industry. Thank you for the inquiry and we will continue to support our clients and our products.”

Follow existing guidelines
It’s clear that these websites, the Facebook page and blog provided no clinical data to support any of their claims. This warning letter isn’t really about Facebook or blogs, but about following existing guidelines. The FDA is very clear on labeling and how companies can promote their products. Companies that continue to follow this guidance (on websites, Facebook and blogs) should be fine

Original article

Social Media Helps Life Technologies Improve Business

Life Technologies’ global senior e-marketing manager for search and social, Robin Smith, explains how the deep relationships the company makes with its fans help influence the products the company makes and how it does business. Their approach is a sustainable way to actively make business better with social media.

Some of her key points:

  • Customers relate to a person, not a company. Making real, human relationships with individuals, as individuals, is key to earning your fans’ trust and opinions. Smith says Life Technologies works hard to let employees have their own voice in social media.
  • A lot of employees shy away from engaging online because they’re afraid of screwing up. Smith explains how the brand helps anyone from an executive to a product manager feel comfortable contributing
  • Social media can change how you do business. Smith talks about how social helped the company launch a product and even come up with a name for it. She explains how your social media fans can be a great resource if you take time to cultivate great relationships.

Healthcare Company Kaiser Permanente Leverages Video

Healthcare company Kaiser Permanente’s director of digital media and syndication, Vince Golla, talked about how the company brought its fans’ genuine, unscripted stories to a bigger audience without hiring an expensive production company.

Some key takeaways from his presentation:

  • You can’t sample healthcare. Kaiser Permanente needed to show people in compelling, honest ways reasons customers love the brand. So the company turned to video testimonials and spotlighting the people who make it great: its staff.
  • Your videos don’t have to be perfect. Golla says to keep the video blog sustainable, the company had to pull production off on its own. So the company hired an indie filmmaker to show the staff some basics and an intern to teach them how to edit it.
  • Make your great content usable everywhere to get the most out of it. Kaiser Permanente didn’t stop at posting videos in social media. The healthcare company played them in waiting rooms, at meetings and on its internal channels to build pride in the content, while still spreading the word.

AMA Social Media Policy

Professionalism in the Use of Social Media

The Internet and social media in particular, have created the ability for medical students and physicians to communicate and share information quickly and to reach millions of people easily. Participating in social media, social networking and other similar Internet opportunities can support physicians’ personal expression, enable individual physicians to have a professional presence online, foster collegiality and camaraderie within the profession, provide opportunity to widely disseminate public health messages and other health communication. Social media, blogs, and other forms of communication online also create new challenges to the patient-physician relationship. Physicians should weigh a number of considerations when maintaining a presence online:

(a) Physicians should be cognizant of standards of patient privacy and confidentiality that must be maintained in all environments, including online, and must refrain from posting identifiable patient information online.

(b) When using the Internet for social networking, physicians should use privacy settings to safeguard personal information and content to the extent possible, but should realize that privacy settings are not absolute and that once on the Internet, content is likely there permanently. Thus, physicians should routinely monitor their own Internet presence to ensure that the personal and professional information on their own sites and, to the extent possible, content posted about them by others, is accurate and appropriate.

(c) If they interact with patients on the Internet, physicians must maintain appropriate boundaries of the patient-physician relationship in accordance with professional ethical guidelines just, as they would in any other context.

(d) To maintain appropriate professional boundaries physicians should consider separating personal and professional content online.

(e) When physicians see content posted by colleagues that appears unprofessional they have a responsibility to bring that content to the attention of the individual, so that he or she can remove it and/or take other appropriate actions. If the behavior significantly violates professional norms and the individual does not take appropriate action to resolve the situation, the physician should report the matter to appropriate authorities.

(f) Physicians must recognize that actions online and content posted may negatively affect their reputations among patients and colleagues, may have consequences for their medical careers (particularly for physicians-in-training and medical students), and can undermine public trust in the medical profession.

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Social Media Helps Doctors Improve Care And Stay Current

Many doctors turn to social media to to stay on top of the information they need to know to provide quality care.

A recent study (Sept. 24) published in the Journal of Medical Internet Research shows that

  • 85% of oncologists and primary care physicians use social media at least once a week or once a day to scan or explore health information.
  • 60% said social media improves the care they deliver.
  • 25% of doctors use social media daily to scan or explore new medical information.
  • 24.1% said they use social media daily to scan or explore new medical information
  • 14.2% contribute information daily
  • 61% scanned and explored and 46% contributed information weekly
  • 58% perceive social media to be beneficial and a good way to get current, high-quality information

Unlike other studies on physician use of social media that tend to lump professional and personal use together, lead author Brian McGowan, PhD, an education technology consultant, and fellow researchers narrowed the focus to how social media can be used for professional development and lifelong learning.

Many doctors prefer closed communities to open social media platforms but according to Bryan Vartabedian, MD, a pediatric gastroenterologist at Baylor College of Medicine in Houston, physicians who limit themselves to closed networks are missing some of social media’s benefits.

“Democratizing media has completely opened my eyes to the experience of the patient,” said Dr. Vartabedian, a co-author of the study. He said his social media connections with patient advocacy groups have given him “a huge appreciation for how they think.”

McGowan said the attention to the dangers of social media and the widespread circulation of a few horror stories have prevented many from embracing it.

  • 20% of physicians think using social media sites is a bad idea
  • 30% think it’s great
  • 50% are undecided and could move toward social media if more studies highlight its positive side

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Moms Trust Blogs

More than two-thirds of mothers consider blogs to be a reliable resource for parenting information

moms trust blogs

Anxious mothers show a tendency to go online in search of answers to an endless litany of questions about raising and caring for their kids. And mothers who looked to the web for parenting advice considered blogs to be the most trustworthy social media platform, according to a July 2012 survey of US online mothers by blog company BlogHer.

More than two-thirds of respondents said they trusted the information and advice gleaned from blogs. Interestingly, faith in blog posts spiked among mothers ages 28 to 45, at 72%, and was a bit lower among both younger and older moms. After blogs, Facebook was the next most trusted social media network at 64%, followed by YouTube at 36%.
Social Media that US Mom Internet Users Trust for Parenting Advice, by Age, July 2012 (% of respondents)

Mothers are not just reading advice online, they’re also taking it. That can mean that a child-specific product or service endorsed on a blog can soon be in a mother’s shopping cart. The most common purchase made as a result of a recommendation on a mom blog was that of a book, at 63%. But BlogHer also found that 56% of moms had made a food purchase based on a blog testimonial, while 48% had bought a baby product.

oms act on blogs

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Farmers Insurance Journey to Social Media ROI

Very informative presentation by Farmers Insurance Group’s Director of Social Media, Ryon Harms.  Ryon shares how they help their agent engage on social media, insure compliance and measuring social media ROI.

Ryon talks about how their Facebook engagement strategy is focused on their people instead of their product and gives examples of how their local agents are connecting daily with customers.

Take out from the presentation:

  1. Social media is about relationships, not product or services, relationships generate ROI
  2. The best social media ideas will probably come from the field
  3. Your employees are valuable resources in your social media programs, don’t cut them off social media, empower them
  4. Don’t write off social media as a business generator
  5. I regulated environments you need to have a system to monitor social media conversations, the same way you need to monitor websites and emails for compliance.