By creating meaningful relationships with individuals and a two-way flow of communication, social media facilitates an intimacy and an immediacy no other communication channel offers — a unique opportunity to connect directly with the public. Social media influencers are an important element of a successful, multifaceted digital engagement strategy. They are critical 21st-century opinion leaders who can be valuable partners in Life Sciences’ companies direct-to-consumer promotional engagement.
Influencers are perceived as genuine, authentic voices, and the trust and authority they enjoy among their followers are powerful tools of persuasion. The strength of their recommendations and the extent to which that drives consumer behavior makes them valuable allies for Life Sciences companies seeking to engage in a different, more effective way with patient populations.
But in introducing a new way to communicate and a fresh connection to the public, social media influencers also present new compliance complications: Risk mitigation with social media influencers is not always well thought-out, which is a tremendous vulnerability to Life Sciences companies operating under a regulatory magnifying glass.
Earlier this year, the U.S. Food and Drug Administration’s Office of Prescription Drug Promotion (OPDP) rolled out a plan to study Instagram influencers and how their commentary is perceived by their fans. The OPDP wants to find out if people are, in fact, influenced to modify their behavior based on recommendations, and if or to what extent disclosures of financial relationships between influencers and companies impact those consumer perceptions. “We are interested in the role of endorsement and payment status on participants’ recall, benefit and risk perceptions, and behavioral intentions,” the agency states.
Already, Life Sciences companies have to withstand considerable scrutiny regarding compensation and disclosures surrounding the opinion leaders with whom they have relationships, via consulting arrangements, promotional speaker bureaus and other channels.
Managing social media influencers demands a unique strategic approach: The very intimacy that makes these individuals so impactful in directing consumer behavior requires an entirely different set of procedural “guard rails” than more traditional promotional messaging. The intimacy and informality of influencers’ communication with their followers is invaluable for its persuasive power, but it also makes appraising that value in a compliant manner a challenging task, given that much of the clout social media influencers wield can seem subjective in ways that valuation of traditional promotional messaging is not.
Calculating Fair Market Value (FMV) compensation can be especially complicated due to the nature of the services an influencer provides, and the kinds of activity they undertake on a company's behalf. Companies need to define and calculate how to determine fair and defensible compensation for influencers who talk about or recommend a pharmaceutical product on behalf of a company.
Following regulations around appropriate disclosure — especially when those regulations are likely to shift in the future as regulatory agencies’ grasp of social media opinion leaders’ work matures — is not something that should be left to chance or tacked onto a broader compliance program with the implicit assumption that the rules will be the same.
Life Sciences companies need to work with third-party vendors that have dedicated resources and a deep well of experience on which to draw when navigating the often ambiguous regulatory guidance on this evolving topic. Working with partners that adopt a consultative approach ensures that you aren’t left to “go it alone” on critical compliance questions.
Solutions like IQVIA Commercial Compliance Consulting Services give companies the tools they need to seamlessly and cohesively integrate influencer promotional activity into compliance-centric promotional operations.