There are a variety of different solutions on the market that seemingly fit the social media “compliance” bill. We often get asked: Which approach to compliance is most appropriate for a company? How a company knows what they really need to ensure their social media efforts are compliant? There are two options when it comes to social media compliance, which we refer to as basic and active compliance.
Basic Compliance
We define basic compliance as archiving all social media communications. This is the absolute bare minimum that companies need in order to be “compliant” within the Healthcare and Life Sciences industry, however there are multiple issues that can arise with a pure archiving solution. While archiving keeps a record of every communication, it does not take action on any post or have a way to identify any risk factors that are present within a social media post. In accordance with FDA and OIG guidance, it is undoubtedly important for a company to retain all records, however this alone is not enough for a company to really understand what is being said on their social media networks and to be 100% protected from compliance risks.
Active Compliance
Active compliance combines the basic solution of archiving with policy management capabilities. Policies are a set of rules that are established by a company to identify, remediate, and archive any potential risk for their company. Policies are designed to protect a company from industry-specific risk factors such as off-label promotion, adverse events, and fair balance product promotion in addition to inappropriate language, malware, personal information, customer complaints, and competitor mentions.
In many cases, healthcare and life sciences companies are using a third party agency in order to monitor their social media presence. Using an agency for compliance is not only very expensive and time consuming, but also leaves room for error. An automated active compliance solution can identify key risk factors in real-time, immediately notify the system administer of these violations, and if desired the post can be removed from the social media network. Through an agency, depending on the volume of posts this process could be very slow and an adverse event or off-label promotion could easily be overlooked. An active compliance solution effectively meets all aspects of compliance as it pertains to social media channels, accounts, and internal collaboration tools through an all-in-one automated and cost effective solution.
Which Approach is Best?
We always recommend to our customers that they use active compliance in order to avoid regulatory fines and sanctions and ensure they are 100% complaint with the guidelines set forth by regulatory bodies such as the FDA and OIG. If a company is early on in their social media strategy and only feels they need an archiving solution, it is important to ensure that the archiving platform comes with the ability to later expand into active compliance capabilities and has the bandwidth to handle a large volume of posts. As social media grows within a company, there is no doubt the need for active compliance will arise and it’s important to have a solution in place that can provide a company with archiving in addition to active compliance, even if those two features are not made active at the same time.
For more information on archiving and policy management, please visit Social Media Compliance & Security for Healthcare and Life Sciences.