New Link Shortener for Risk Info

Update: Comments on this post pointed out an error. A new blog post explains that error and provides further information on the use of URL shorteners. http://regulatoryrx.blogspot.com/2014/09/why-url-shorteners-matter.html

inVentiv Health has a new link shortener that appears to make a very valuable contribution to the use of Twitter by pharmaceutical companies.

As I've talked about extensively (e.g., here, here, and here), there are difficulties with trying to follow the FDA social media guidance on the presentation of risk information in space-constrained contexts because of how much stuff FDA wants included in any single message.

Specifically, FDA says messages must include:
1. Brand name
2. Generic name
3. Non-misleading indication statement
4. Abbreviated risk statement
5. Link to complete risk information

In FDA's own example, just including all of the required elements takes up 134 of the 140 characters available for a single message.

NoFocus (rememberine HCl) for mild to moderate memory loss-May cause seizures in patients with a seizure disorder www.nofocus.com/risk (page 14)

And FDA explicitly discourages the use of URL shorteners out of concern that the shorteners will obscure the nature of the information being linked to.

The Agency does not intend to object to the use of such URL shortening services; however, when possible, the Agency recommends that the URL or web address itself denote to the user that the landing page consists of risk information (e.g., www.product.com/risk). (page 10)

That puts sponsors in a bind because using the FDA's example, there were only six characters for the actual message itself after meeting the regulatory requirements.

inVentiv's solution is quite clever. It provides the benefits of a URL shortener while addressing the objection from FDA that such shorteners tend to obscure the information in the destination.

The shortener from inVentiv appends to a root of "RxRi.sk/" a short character string to a specific page dedicated to risk information. By including both the standard abbreviation of Rx for a prescription drug and taking advantage of the top-level domain for Slovakia (.sk), combined with the two characters Ri, the shortener clearly communicates that the destination location will include risk information about a prescription product without using nearly as many characters as the FDA's example.

In a few tests, the shortened string appears to have a consistent 13 characters vs. the 20 characters in FDA's product name. Of course, the FDA's example included the unnecessary characters "www." at the beginning of the URL, so even FDA's example is really only 16 characters in length.

Is a three-character saving really that big a deal?

Yes, I think it is, and I think there are a few reasons for that. First, every character matters when we're dealing with Twitter. Shaving a few characters here and a few there will add up and make for a far more flexible framework.

Second, inVentiv is making this shortener available to everyone free of charge. Consequently, this can become an industry standard if people are willing to adopt it, and having consistency in such communication platforms will make it far easier for people, especially consumers who don't spend all day thinking about how the FDA regulates prescription drugs, but who just know that Tweets from the medicine they're taking include scary information. For them, gaining familiarity that drugs have risks, and here is where they can find the risks associated with their particular medicine is valuable.

Third, the three-character improvement is for FDA's fictional product name of "NoFocus." FDA's actual recommendation is to always include both the product name and the word "risk" in the URL that directs users to the full risk information. "NoFocus" has seven characters. That seems to be the norm for top brands, as a quick scan of the top 10 selling drugs in the past year reveals three names with six characters, three with seven, and two with eight characters. There are, however, some drugs with much longer names, and if you're marketing a product with 10 or 11 characters in the name (of an extended release version with an "XR" added to the URL) the savings can add up.

Having a standard means of providing this information takes one item off the table when drug names are being created and evaluated.

Of course, some of these benefits are only realized if in fact people adopt inVentiv's shortener and make it a standard. We'll see whether that happens or whether some additional competing services emerge. At the very least, inVentiv has moved the conversation one step forward.