Medsider: Learn from Medtech and Healthtech Founders and CEOs - Social Media Best Practices for Marketing Medical Devices

Episode Date: April 10, 2013

Did you know the FDA recently issued a multi-million dollar contract to a private company that will be charged with monitoring social media? Yes, multi-million. Needless to say, that’s a si...gnificant amount of money. Although many would argue the FDA has not been very clear regarding its guidance towards social media, you can’t deny that...[read more]Related ArticlesCan Nurep Solve the Inefficiency Problem in Medical Device Sales?Can Medical Device Companies Increase Sales and Reduce Costs at the Same Time?Substantial and Sustainable – 2 Words That Medtech Companies Should Get Used To 

Transcript
Discussion (0)
Starting point is 00:00:00 Welcome to Medsider, where you can learn from a mix of experienced medical device and med tech experts. These proven mentors will show you how to master the med tech space on your own terms without going to school. Now, here's your host, Scott Nelson. Did you know that the FDA recently issued a multimillion dollar contract to a private company that will be charged with monitoring social media? Yes, multimillion. Needless to say, that's a significant amount. of money. Although many would argue the FDA has not been very clear regarding its guidance towards social media, you can't deny that the FDA is beginning to take social media more
Starting point is 00:00:43 serious than it ever has. In this interview with Dr. Mukesh Kumar, Senior Director of Regulatory Affairs for AmeriX Clinical Research, we'll discuss common issues, misconceptions, and possible solutions in regards to using social media to market and sell FDA-regulated medical devices. Here are a few things that we're going to learn. Why one particular company received a warning letter from the FDA for clicking the Facebook like button. Trends and recent discussions regarding the FDA's overview and enforcement of social media as it pertains to marketing medical devices. Best practices for managing social media within the medical device space.
Starting point is 00:01:22 If a patient submits a question regarding a medical device via Twitter, how is it possible to present balanced information given the 140 character limit? Of course, there's much more that we'll cover in this interview. you, but before we dig in, please listen to these brief two messages. Job leads, opportunities to network, access to specialized groups, meaningful discussion and debate, sound interesting, then you should check out the medical devices group on LinkedIn. It's the industry's only spam-free, curated form for intelligent conversations with medical device thought leaders.
Starting point is 00:01:56 Not only that, but it's the single largest medical group on all of LinkedIn. Medical device professionals worldwide are invited to join. join the Medical Devices Group to help build their personal and corporate brands. Check it out. Medical Devicesgroup.net. Again, that's medical devices group.net. As a reminder, MedSider is on iTunes. Just go to Medsider.com forward slash iTunes and you could subscribe to the podcast for free. That way, all the new episodes will automatically download to your iTunes account. It's super easy. Also, if you like the podcast, don't forget to rate it. That really helps us out. Okay. For you ambitious, MedTech and
Starting point is 00:02:34 medical device doers, here's your program. All right, hello, hello, everyone. Welcome to another edition of MedSider. Of course, this is your host, Scott Nelson. And for those of you who are new to the program, MedSider is a place where I interview medical device and med tech thought leaders on a wide variety of subjects. And in this particular episode,
Starting point is 00:02:52 we're going to cover all things social media as it pertains to FDA-regulated medical devices. And the guest on the program today is Dr. Mukesh Kumar, who is the senior director. of regulatory affairs and quality assurance for Ameriq clinical research. Dr. Kumar, his key expertise is in global regulatory and business processes for medical and diagnostic products. He's a well-known expert in global drug approval processes as well and has been involved in clinical
Starting point is 00:03:24 trials in more than 60 countries. And lastly, Dr. Kumar is a PhD in biochemistry with a specialization in virology gene therapy in molecular biology. Hopefully I got all that in. But welcome to the program, Dr. Kumar. I really appreciate you coming on. Thank you, Scott. It's a pleasure being here.
Starting point is 00:03:42 That was a rather long-winded intro, but I needed to make sure I fit in as much as possible in your background because it's pretty impressive. But as I just mentioned, we're going to talk about all things social media as it pertains to medical devices, medical products, et cetera, that are regulated by the FDA.
Starting point is 00:04:02 But before we dig in specifically, I think you've got an interesting story in regards to a device that was recently on Graves Anatomy as it pertains to social media. So why don't you go ahead and explain that story? That is correct. Well, Dr. Paul, thanks for having me here, and it's a pleasure to talk about a topic. That comes on and off more often these days regarding the use of social media to market medical products. It's not just true for medical devices, but any kind of product and any kind of marketing for a given product that's done, more and more people are using social media. And when we think of social media, we typically think of Facebook and media like their Twitter's and Facebook.
Starting point is 00:04:48 But social media is more bigger than that. Social media is anything that is in the public domain on a website or on a TV or radio program. that could be considered as an advertisement or marketing of a given product. You mentioned an interesting story. There was a warning letter issued by FDA to a manufacturer of a medical device in California. And I won't take the names of public information, but what happened was this company was working on a cardiac medical device and they were conducting clinical trials with it.
Starting point is 00:05:28 and their principal investigator knew someone as one of the writers on Grey's Anatomy, and he plugged the device on one of the episodes of Grey's Anatomy, in which the actors, in the plot of the soap opera, the actors used that device to treat a patient. And the PI acted as a consultant, and PI also had a brief appearance on that episode. somehow FDA got to know about it and the company got warning letter for advertising their product, their investigation product on a TV program, on a national TV program. It came as a big surprise to people like us who follow the industry and follow FDA's rulings
Starting point is 00:06:13 because this is the first time ever we have seen FDA go after something so vague like that, something where a TV episode is obviously highly edited and the information on it is really, really very brief about any device, and it's very hard for patients to recognize a device based on its description on a TV, fictional TV program, but FDA considered that as a risk. There have been many other episodes mostly related to Facebook pages and Twitters, where actually FDC just yesterday released. a new guidance on mobile advertisement, advertisement that appears on telephones, smartphones and so on, which is very interesting to see.
Starting point is 00:07:01 So with that, I mean, let's go into the specifics of the process, but it is getting into a lot of areas where regulators traditionally did not go. And they are getting more and more aggressive about enforcing these new not yet described regulatory. on a case-by-case basis. Hmm. Yeah, that's interesting because it would seem that that is a fairly innocent sort of occurrence for a device to be sort of plugged or showcased in grades anatomy. But it's clear that the FDA is watching and taking action, you know, in this particular circumstance, as you just mentioned, because the manufacturer received a warning letter, which is interesting.
Starting point is 00:07:46 Yes, and FDA also actually recently recently. Also actually, recently, actually this week, FDA gave contract to a private company to monitor social media, to monitor Facebook, Twitter, and all that. FDA actually gave formally a contract worth, I think, about $2 million per year to a company, to an advertising company, to basically go out and monitor Twitter and Facebook and LinkedIn and any other social media, TV, radio, for seeing incidences of, of, product placement, product advertisement, product promotion. So we could expect a lot more aggressiveness from the agency in the coming times. Yeah, yeah, no doubt. I have not read about that release in regards to issuing of that contract, so that's definitely interesting.
Starting point is 00:08:37 So let's go and dig in. There's clearly risks and benefits to utilizing social media if you're a medical device manufacturer. So let's get into some of those risks and then contrast those to the obvious benefits of utilizing some of these channels. Sure. Well, okay, in terms of let's look at the intent of regulators. The regulators are very concerned about off-level use of devices, off-level use of any product for that matter. But let's look at devices because it's more prone in devices than in other products. What the agency wants to make sure is that manufacturer, first of all, say whatever they want to say about their device in a way that's non-misleading.
Starting point is 00:09:28 And when something is presented in a brief format, when something is presented on Twitter, where you have a very short message that needs to go on it, or even on a website where the consumer has to scroll or has to sometimes hit multiple links before they get all the information. about a given product, it is possible that the consumer may not know everything about a device or a product before they decide to use it. So for that reason, all the regulations, so far there is no written regulation. It is more on a case-by-case basis. There are two guidance documents in the works that the agency has assured will be released this year, but they have been still enforcing the advertising.
Starting point is 00:10:16 using various different regulations for the last at least two, three years. What they have been asking the manufacturers is to assure that all the disclaimers, all the pros and cons, all the risks and benefits of a given product are adequately informed to a consumer in any form of advertising. And it is very, very hard for manufacturers to do that on something like Twitter or even on Facebook, where you have very little control on what's going to get posted by your users, by your connections. For example, there was a warning letter given out in September of 2012, I think, sometime last year, where a manufacturer got a warning letter for hitting like on a comment.
Starting point is 00:11:05 So there was Facebook for a product, and a consumer posted some benefit that they got from using the product. So they posted a comment, and the manufacturer, hit like on that comment. And FDA gave a warning letter saying that by hitting like the manufacturer was endorsing that off-level use. Now, you can imagine, I mean, this is something could be again looked at as extremely innocent as, you know, they found a comment that was very favorable to their product and they hit like on it. And they took it as endorsement of that comment which was off-level use of the device. So because again, coming back to the intent, The agency is very worried that manufacturers could mislead the consumers because since it
Starting point is 00:11:48 was off-label, and by definition, off-label means that this is a use that has not been thoroughly reviewed by the agency in terms of its risk and benefits. So they are worried about manufacturers telling consumers something that they have not vetted, and because of that, they are getting extremely aggressive on anything that they feel would do that. And because social media is very new, the agency, acknowledges agency even uses. I mean, FDA has all kinds of applications of social media. FDA uses Twitter itself to release information. They use Facebook. They have blogs. They have all
Starting point is 00:12:28 kinds of ways to talk about their initiatives. So they are very aware of the power of social media. And because of that, they are also very aware of the potential for misuse of this media and kind of going around the agency, talking about things that they don't want people to talk unless they have verified it. So in terms of FDA have released a couple of guidance documents. One of them was specifically about off-level use, which goes at length about how to address a use that has not been approved by FDA. There are certain advantages to the consumer about these off-label uses. Many medical devices have off-level uses. So FDA does acknowledge and actually the commissioner, FDA commissioner, Dr. Hamburg, actually
Starting point is 00:13:15 went to a congressional hearing and very vocally said that the FDA does not want physicians to not be able to use a product off-level if they feel a patient can benefit from it. But they certainly want manufacturers to not use that information for financial gains. So agency has been saying that while they're okay with off-label uses, they know off-label uses exist and they know these uses benefit patients, but they do not want those uses to be commercially used by manufacturers. So the way it is done right now is if an off-level information is generally known and physicians do it on their own without any active inducement by the manufacturers,
Starting point is 00:13:57 then there is no problem with off-level use. Problem happens when manufacturers go out and actively talk about that off-level use without getting the agency's blessing on it. So this guidance document that has talks at length. It's a pretty detailed guidance document, and it covers all kinds of FDA regulated products, and it talks about the rules that the manufacturer has to follow when they encounter an off-level use off-a-product.
Starting point is 00:14:24 Got it. The one that I talked about, the one that was released by FTC on 26th of March just a couple of days ago, that talks about the dot. It's called the dot com guidance. And in this guidance, the FTC actually is talking about what in what forms, what should be the font size, what should be the zoomability,
Starting point is 00:14:50 what should be the positioning of text when looked at on mobile devices. So they're talking of, you know, on smartphones. They know lots of people do see a lot of information on their smartphones, they read emails, they watch web pages online. So this whole guidance, this is a 50-page guidance that came out of FTC, which talks about promotion of products and having a disclaimer information available. And it is assumed that FDA did play a big role in writing of the guidance, and this FTC guidance is going to, a lot of
Starting point is 00:15:26 it is going to reflect in the FDA's guidance that is expected later this year. Okay, okay. So basically there's two different documents or, guidance documents to date, but there's going to be a third guidance document that the FDA will hopefully release later this year in 2013 to shed more light on this topic? Yeah, there are two guidance documents that are directly going to be in this domain. One is going to be a domain on social media use, use Facebook, Twitters, and all. And the other one is specifically on mobile applications, on apps that you have for, you know, smartphones or iPads or notepad on tablets.
Starting point is 00:16:09 That guidance is also in the worst, which will specifically address how should those applications be designed so that they can still be useful without, as again, misleading the consumer. Got it, got it. So, yeah, and that'll be interesting. I almost wonder if we should have a follow-up interview later down the road when the FDA initially does release that guidance document. But for now, I want to go back to a comment that you made earlier.
Starting point is 00:16:34 or a couple comments that you made earlier in regards to the fact that a medical device manufacturer needs to sort of empathize with the FDA in terms of how they're viewing social media. And so correct me if I'm wrong, but it sounds like the FDA's main concern is not misleading the consumer, especially as it pertains to off-label promotion of products of medical devices. But it sounds like they're trying to take existing requirements, existing like an existing paradigm through traditional marketing channels and trying to apply that to social media, which is really quite different and very iterative. Sorry, I'm not supposed to say that word this afternoon here, but social media changes so
Starting point is 00:17:20 often. It's really more about listening to customers versus actually marketing. So that seems like a rather difficult task to accomplish for medical device manufacturer or to stay within the traditional confines of FDA regulations that patients medical devices, but somehow being able to utilize social channels to engage with potential patients, potential customers. So with that said, are you, are there some best practices
Starting point is 00:17:51 that you're seeing or maybe that you encourage some of your clients to take on in terms of utilizing? the various social channels to market or to promote medical devices? Yes, yes. Actually, FDA is not averse to manufacturers using social media to market their devices, provided they know about it. So what we do advise is, of course, sending everything to the Office of Prescription, drug promotion or actually the Office of Device promotion within the CDRH for medical devices. If you are planning to have a Facebook page, for example, for your product, And many products do have Facebook pages.
Starting point is 00:18:31 If you are planning to have that or if you're planning to have, you know, a website dedicated to your product, then submitting all the content that's going to appear on the website and actually submitting a potential website with all its color schemes and all the different links on it, sending it to FDA's advertisement division for review before releasing them is always a very good idea. If you are going to allow consumer forums, if you're going to allow things where people can post comments, either on your website or on your Facebook, then you certainly want to make sure to have some kind of control, some kind of review of any information. So, for example, we talked earlier about somebody hitting like on a comment on their Facebook page. So, you know, of course, they didn't know this could be considered as a bad thing. But now that we know, companies should have standard processes for managing their outlets, their information outlets, no matter what they are.
Starting point is 00:19:39 So having standard processes, first thing, of course, when you initiate something, having the agency look at it and let you know if there is anything objectionable and obviously listening to them and revising it. And second is to have standard processes where you define it. what are your do's and don'ts for your information outlets. And third thing is to have individuals who are experienced and who are trained to monitor those things, to look for those kind of red flag issues.
Starting point is 00:20:14 For example, if you see an off-level promotion, an off-level use of a device being discussed on a forum that you run, then it's very important for someone from within your staff, staff because this is your website to post right away a disclaimer information that this is off-level and the company does not endorse it. And actually, they do mention that in their off-level promotion, off-label guidance, that whenever a manufacturer encounters becomes aware of off-level information, either from a public or a private, somebody individually contacting the company, or any of the ways, if the company
Starting point is 00:20:52 becomes aware of an off-level use, they are supposed to provide. full disclosure to the requester of the off-level information, which includes providing, you know, first of all telling them that it is not something that has been approved by FDA, so there could be risks that they are not aware of. Second, directing them to R&D staff and not to marketing staff in terms of, you know, the tone of the information that goes out, and also providing any other information that the manufacturer may be aware of, even information that may not be very far away. to your device, providing all the information, and then documenting it in detail.
Starting point is 00:21:31 So there is a very formal process out there to manage off-level information. And very similar rules apply to social media. When you encounter something off-level social media, then you want to certainly address it. Now I should point out that although I keep mentioning off-level views, even for on-level views, very important to have certain rules when you talk about social media. Another fraud alert, actually, there was a fraud alert that came out of the Office of Inspector General within the DHS yesterday, March 26th, which talks about a physician-owned distributorships of medical devices and products.
Starting point is 00:22:19 Now, for medical devices, it's very common for physicians to invent medical devices. Many medical devices are invented by doctors who use them on their patients. Many medical devices are sold through physicians, through manufacturers. Manufacturers talk about usually go to a physician and offer them a device and so on. So any time a physician has a stake in a medical device, as an investor, as somebody who gets a commission on sales of devices, or any other financial relationship for the distributorship of a device, even if it is on-level, there is a fraud alert, a special fraud alert by OIG, especially discouraging their practice, especially talking about when a physician, because what was found was, in cases where physicians
Starting point is 00:23:04 were also distributors of a medical device, they were giving the device a lot more, they were prescribing the device a lot more than it was necessary. There were necessary operations, there were unnecessary sales. there were times where sales were very highly aggressive on the consumers. So actually there is, and this actually directly plays into the anti-kickback laws that exist in this country, which under which anybody who gets, you know, gets a kickback for sale of a device, either as a commission or any other reason, that's considered illegal for medical products. So there is a special precaution for all medical device operations.
Starting point is 00:23:49 You know, when you talk to your sales agents, when you have marketing people go out and get physicians on board to sell your devices, make sure that those are looked at by lawyers and looked at by somebody, an anti-kickback specialist, to make sure that you're not getting in that gray area where you could get in trouble. In the Office of the General is investigating those things very, very closely. So it's not just off-level, even on-level. So if you have a physician, many physicians have Facebook pages, many physicians have, you know, patients, you know, websites where they talk about what they do
Starting point is 00:24:26 or whatever, and they make a presentation somewhere or any kind of expertise they attain, just make sure that those also get reviewed because they do impact your device. Got it, got it. And you would be liable for it according to the FDA. Okay. So let's go back to some of these best practices that you mentioned. Just to review, number one was submit all content that you're building out for your social media site, whether it's YouTube, Facebook, Twitter, et cetera, submit all that contact for review by the FDA or by CDRH.
Starting point is 00:25:03 The second best practice would be to have standard processes in place internally for your social media outlets. And then third would be have experienced people on hand that are ready to monitor your various social media channels in order to make sure that you as a company are abiding by the FDA standards when it comes to both on-label and off-label promotion. Does I sum that up okay? That is correct. So I want to actually ask a specific because this question actually came in from our audience in advance of this interview.
Starting point is 00:25:40 for those listening, if you do have a question in advance of the interview, there's a new tab on MedSiter.com that allows you to actually submit a question in advance of the interview. But this question comes, and I'm just going to read it here to you, Dr. Kumar. It says if a patient submit the question regarding a device via Twitter, how is it possible to present balanced information on indications, risk, benefits, et cetera, given the 140 character limit. How would you bet you answer that question? Very good question. Actually, there is a very clear direction from FDA in that. The direction is you reply to it by directing them to the right department at your organization. So you don't have to give them
Starting point is 00:26:26 all the response. What you do is you tell them please contact this individual in our R&D department to get the complete information. Don't try to reply with anything other than that. And actually they even provide examples of the kind of language they want to use, which should be pretty much non-soliciting, non-committing in any direction. So that's a simple rule for something like Twitter. And that applies to even Facebook comments. When you get a comment, you know, there is a limit as to how big a text you can type into that box. And, you know, there would be always a problem. So you always send them the contact. information and tell them please send your question to this individual at this email address
Starting point is 00:27:11 and we would send you the detailed information and only then send that information. That's great stuff. So instead of feeling like you have to respond and actually answer that question via Twitter or through the limited number of characters on a Facebook comment, for example, it's best to either address them to a certain department or maybe even direct them to a particular web page that has content that's already approved. Yes, absolutely. Would that be another way?
Starting point is 00:27:38 Okay. Yes, that would be another way. Absolutely. I mean, anything that's already, you know is pristine, you know it's Gorsher, send it to that website and send them to that location instead of trying to respond right there. Got it, got it. Okay. And I guess this is a nice segue way to another question that came in advance of this interview
Starting point is 00:27:56 from the audience. I'll read it to you again here. If misinformation, or let's call it maybe off-label information, it's possible information, it's posted on a site for a particular medical device. Is it the company's responsibility to address it, even though they maybe aren't the owner of that particular website? Well, it's a great area. If the website is owned by the manufacturer, then yes,
Starting point is 00:28:27 they need to respond because they are responsible for anything that's posted on the website. But if the information is posted on a publicly held website, something like, let's say there is a consumer forum, and within that forum people post information about a device or a drug, the company does not have any liability so long as it does not participate in those responding. If they do not say yes or no or anything like that, if they do not support, and if they do not say anything in either way, being negative or positive, they stay out of it, then they
Starting point is 00:29:00 don't have any – because there are several consumer forums on the web, on the – on line, which may talk about many different users and it is not reasonable and actually the agency agrees that it is not fair to expect a company to know everything that's out there on the billions of pages out there. So what they do expect is if it's your website and somebody posts on your Facebook page or your website or a forum that you created, then yes, you should address it, you should correct as I said earlier, respond by posting a note saying that this information is off-level and it's not been verified by FTA so that it's clear that you are not endorsing it.
Starting point is 00:29:44 But if it is not controlled by you, if it's a public blogosphere somewhere, then you don't have any liabilities. Got it, got it. Okay. Yeah, that makes sense. It's not like a device company or a pharma company, you know, whatever health care company or whatever umbrella you fall under. It's not like you have to feel like you have to monitor every single web property on the Internet.
Starting point is 00:30:07 It's just basically the web property is that you own and produce content for. You need to make sure that everything is legit and approved by the respective regulatory agency. That is correct. That is correct. You know, there was recently another congressional hearing where the CDRH's director was asked a question that many a time device manufacturers are well aware of an off-label use of their device, and how does the agency approach it? And the answer was that, you know, unless a device manufacturer goes out and actively markets a device for off-label use,
Starting point is 00:30:46 there is no restriction on doctors using a device in an off-label fashion. So even though the manufacturer may be aware of it, they don't have to go out and specifically get an approval for that off-label use or do anything else other than not participate in marketing. The agency is very clear that they do not want to restrict doctors from using any product that could help a patient. The only condition they have, which is what I talked earlier about the physician-owned distributorships,
Starting point is 00:31:18 and they call it POD, the physician-owned distribution, P-O-D. And in the case of a P-D, agency certainly considers the physician now, no longer a physician but actually a manufacturer or a distributor. So their liabilities change. Okay. Other than that, if a physician is using your device for off-level and you know that it can be used but there is nothing you can do,
Starting point is 00:31:44 you're not marketing it for that purpose, you don't have much liability in that case. Got it, got it, okay. And I want to go back to kind of the second best practice that you mentioned earlier in regards to having standard processes in place. Now, in your experience in helping some of your clients deal with this issue with social media and marketing of FDA regulated products, are there, without going into, I guess, too much detail,
Starting point is 00:32:17 are there some standard processes that come to mind that are worthy of commenting on right now? In terms of social media, there are certain things I always advise people not to do. So I advise them to stay out of Twitter because it's very restricting in terms of how much you can post. And it always hurts you. So I always tell people that don't use Twitter too much to market your device, actually stay away from it and tell your management and your personnel to not use that to talk about your products. Also, I also tell my clients to stay away from solicited blogs, blogs that you pay for.
Starting point is 00:33:02 You have a paid author blogging about your device. I do tell them to stay away from it because it can be, you know, somebody saying something, unless you control every word, somebody writes, it could potentially do some landmines for you later. A third thing that actually is going to also become much, much, much, much, much, much less now because of the Sunshine Act. Within the Affordable Care Act, there is a provision for sunshine disclosures
Starting point is 00:33:30 where manufacturers are supposed to disclose any payments made to physicians, any payments of any kind, including payments for clinical trials. So it's a very, very expanded Sunshine Act, expanded in terms of what used to exist in certain states, where when physicians are involved in talking about your product,
Starting point is 00:33:51 it could lead to issues for the physicians and for the manufacturers' legal liability issues. So in general practices, I tell people to stay away from these three things. Stay away from Twitter, stay away from solicitive blogs, and stay away from hiding physicians to talk about your product because even a good product could get bad name because of bad practices. Other than that, as I said earlier, having the content, reviewed by the agency, having the practices to avoid any kickback issues, and training people appropriately addresses most issues. Got it.
Starting point is 00:34:34 Got it. Okay. And as we reached towards a conclusion to hear this interview, there's another question that I want to make sure I answer. I thought it was really good. That was one of our audience members submitted in advance. And again, I'll read it off here to you. Of course, we all know medical device companies are required to
Starting point is 00:34:51 report adverse events to the FDA. If unidentified patients post comments regarding adverse events on a website not controlled by the medical device company, is that company then required to report the event to the FDA or attempt to contact a patient? Well, yes and no, and I'm sorry for being so vague about it. In terms of liability of a manufacturer for an unidentified patient, anonymous patient posting an adverse event, legally there is no liability for the manufacturer. Manufacturers are supposed to report any complaints they get directly, but not what somebody
Starting point is 00:35:33 posted on some website that they don't even know who's the poster. But at the same time, that's why my no answer. In terms of if the complaint is similar to what they have heard from other patients that did report to the manufacturer directly and the manufacturer becomes aware of some additional complaints out there that they cannot verify but they may be out there. They should discuss their post-marketing plans. They should look at their post-marketing commitments, what they made to the agency if they made any, about what their commitments are.
Starting point is 00:36:11 Because if the post-marketing commitment is to collect all 50 information and let of the NO, then they may have to make a submission. to their post-marketing study, letting the agency know that they have become aware of this adverse event that they are trying to verify, but they don't know what it is about. It is very similar to when you do clinical trials and you have lost to follow up. In clinical trials, all the time,
Starting point is 00:36:40 that a patient has an adverse event. Somebody called, maybe the patient himself or herself called you and said, I don't want to come again because I had this adverse event. And the patient refuses to come back to you and you call the patient multiple times. You try to reach out to patient, but the patient is not traceable. And what we do in that case is we actually let the agency know that we did all things reasonable to contact this patient, but we are not able to. So we're calling it lost to follow up. Something very similar applies to this kind of side effects that you talked about. So there could be cases where, you know,
Starting point is 00:37:17 where manufacturer may have to do something more. I would advise them to, you know, look at their, talk to their regulatory consultants and see what the right approach, depending on the adverse event. I mean, more severe the adverse event, the more worried should be you. Simple as that.
Starting point is 00:37:32 If it is something like somebody died or somebody is claiming that they had, like, serious disability, which would be considered as a major adverse event, then I would suggest, for your own sake, try to find out if you can. Got it. Got it.
Starting point is 00:37:46 Okay. Very good. And then lastly, before we end this interesting interview, it's obviously a challenge for medical device companies to utilize social media, a lot more difficult than other verticals, you know, if they tech or education or, you know, name your other vertical. It's a lot more challenging for device companies. Having said that, there appears to be, you know, a lot of benefits, too,
Starting point is 00:38:16 to utilize social media. So what are you, what's your take in summary in regards to medical device companies and whether or not they should jump into social media? Oh, I think you cannot hide from it. Social media is here to stay. I mean, these people are going to talk about your product on Facebook, on Twitter, or on everywhere else. And you should certainly take advantage of this very, very valuable tool to be. talk about you. Absolutely. I encourage people to use any technology out there to talk about their product with all the precautions that I mentioned, you know, taking care that you don't,
Starting point is 00:39:02 you don't get accused of doing something that is illegal. But social media is something that is going to stay. I mean, I don't think a company can hide from social media. Even if you don't have your own Facebook pages or you decide, you would still want to have a a website, I'm sure most products have websites these days, you want to control information. I think it's very, very important for a manufacturer to realize that in this information age, you want to control information, both good and bad, because what you don't want is somebody badmouting about your product on a social media incorrectly, somebody saying something bad about your product, which is not true. So it could be used in both the positive and negative ways.
Starting point is 00:39:45 So you should certainly, I think the first thing you should do is definitely look at, you know, what are the most appropriate social media tools for you. I'm all for websites. I'm all for, you know, having YouTube videos, talking about users. I'm also for having Facebook pages. I'm a little biased against Twitter because of the limit of the amount of information you can post. So the only thing you can post on it is a web link or contact information due to the limit. in correctors. I'm also a little skeptical about any other media which controls, you know,
Starting point is 00:40:22 the accuracy of information. If it is uncontrolled information, there is good chance of error in that information. So I think companies should certainly investigate and try to have social media departments within themselves, where they have individuals who help them come up with a social media plan, individuals who monitor social media, and also who make sure that whenever needed they get appropriate approvals and are trained to do those kind of things. So, I mean, I personally believe that if you are not going to do it, you're probably going to get hurt more than you want, because it is here to stay. Yep, yep.
Starting point is 00:41:09 No, no, that's a great summary. And like you just mentioned, I think if device companies don't jump on board, they're certainly going to be much further behind in comparison to their competitors that have already embraced social media but are doing it properly and under the correct guidelines and requirements as introduced by the regulatory agencies. So cool, very good. Well, let's call it good, Dr. Kumar. But for those listening that I've stuck through and listened to this part of the interview,
Starting point is 00:41:45 where's the best place for them to learn more about Amerex, to learn more about you? Where do you want to direct the audience to? Well, you know, if you are going to give out, I would say, you know, going to the website of the company is a good place to know what AmerX does. I mean, my contact information, please make it available. And if somebody has a question that I can help with, I'm more than happy to do that. There are seminars that I've done on this topic. So if you Google, you'll find, you know, if you Google my name and social media,
Starting point is 00:42:22 you'll probably find links to those webinars. These are web-based seminars that have done on this topic talking about the FDA's guidances. and there are others that I'm planning to do in the near future. So I would say, you know, there are several ways to reach out to me and my company to find out more about it, about these things. We do consult with many clients on these aspects these days because this is very, very important for pretty much every aspect of this industry, from clinical trials to marketing and post-marketing and so on. And actually, this is a very important marketing technology these days, particularly in the international scene, because we have way too many clients who are based in one country, but they have customers based in other countries who found out about them from websites by searching.
Starting point is 00:43:17 So it has certainly a significant benefit to the users, to the benefactors. to the manufacturers. Of course, you know, everything comes with its own limitations. It's not used properly. Sure, sure. That makes sense. So just those listening, yeah, I mean, I certainly did the same. You can certainly Google Dr. Kumar's name and social media,
Starting point is 00:43:43 and there'll be a whole list of various websites that he's been featured on or done presentations for or webinars for it. It's Dr. Mukesh Kumar, M-U-K-E-E-E-E. is his first name, last name is Kumar, K-U-M-A-R, and I'll, of course, link up to the website, you know, for the show notes for this particular interview. And then Dr. Kumar, why don't you go and give the website for Amer-X? Yes, it's www.am-A-M-A-R-E-X-C-R-O.com. and my email, direct email is M-U-K-E-S-H-K at Amarex C-R-O.com. Got it.
Starting point is 00:44:34 Okay, so it's just your first name and then K. Muked-K-K at Ameri-R-O.com. That is correct. Got it. Very good. Well, thanks a ton, for coming on the program, Dr. Kumar. I really appreciate your insight. You can tell that you've spent a lot of time.
Starting point is 00:44:52 studying this topic and are very, very knowledgeable in regards to the use of social media pertaining to a highly regulatory industry like the medical device base. So thanks again for coming on. Really appreciate it. Thank you, Scott. It's a pleasure. All right, that's it, folks. Hope you enjoyed the interview.
Starting point is 00:45:13 And one last reminder, we are on iTunes. Just do a search on iTunes for MedSyder, and you could subscribe to the podcast for free. That way, all the new interviews will obviously. automatically download to your iTunes account. It's super easy. All right, until the next episode of Medsider, remember, don't just sit in the audience of life. Be ambitious. Take some action.

There aren't comments yet for this episode. Click on any sentence in the transcript to leave a comment.