A while back, pharma companies/marketers operated under an assumed framework that if more complete disclosure about named drugs was one-click away (the “one click” rule) on the web, that should be sufficient. A series of FDA warning letters eventually put the freeze on that notion.
However, in a hyperlinked world, I think that compliance and disclosure via hyperlinks is the only logical method to both enter into the fragmented world of web communications, AND provide full information for patients and physicians. Anyone who has seen printed product information (the “PI”) littering pages of magazines (following a drug ad) immediately understands that providing all of that disclosure in web formats – esp. social media – is totally unrealistic.
Today, a new service was announced which really got me thinking. Check out http://cmp.ly/ – in fact, first read this overview. Having standardized shortened URLs to deal with new FTC requirements for blogger disclosure is a brilliant idea. But I think this has the potential to go much further, by providing a standardized method for hyperlinked disclosures for pharma (and other regulated industries).
Let’s say that a pharma company has 5 corporate disclosure documents that are universally used, and that the company has 4 products, each with a PI. Every one of those documents can have a fixed and predictable link, so that in tweets on Twitter, in blog posts, or in Google ad links, those disclosure documents are “1-click” accessible.
This can be a paid service for a company like those who launched cmp.ly. Let’s say your the first pharma company to pay for this linking/forwarding service. You get http://p1.cmp.ly. A corporate disclosure statement can then be at You get http://p1.cmp.ly/1. A specific product PI could be at http://p1.cmp.ly/5. And onward – the 30th company to sign up would be at http://p30.cmp.ly, etc.
Device companies? d(x).cmp.ly, etc. Banks? b(x).comp.ly, etc.
Frankly, I don’t see any alternative to something like a “one-click rule” – it was never official before, and never standardized, but an approach like this might make it easier for the FDA to get comfortable with the notion.
What do you think?
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