On the other hand, giving up the opportunity to learn directly from customers seems like a huge missed opportunity. Don't we want to understand patients better? Don't we want to build trust through dialogue? Pharmaceutical companies must be able to listen to these voices online. That's how they can gain insights and create better treatments.

Here are two types of monitoring the FDA should allow without any reporting requirement.

• Sample monitoring to capture anecdotal, qualitative discussions about the issues patients and doctors are sharing in blogs and other personal media. With no attempt to be comprehensive, this "spot listening" can tune companies into what some consumers are saying. There could be a limit to the number of discussion sources that we listen to in any given week. This would allow pharmas to identify key influencers (i.e., well-linked blogs) as well as a sample of everyday bloggers to have a clearer sense of their interests. Since this approach offers a narrow view, it could not be assumed that any problem reflected in a single blog is endemic of larger product problems. (On the other hand, the most altruistic pharmaceutical executive might welcome this approach as an early warning system of potential patient or physician problems).
• Complete monitoring - share of voice, top sites, top mentions, comparison of discussion - all on conditions or issues without any mention of the company's product. This will offer potential insights into how people are coping with a condition without the compromising data associated with a specific product. Most tools can be programmed to deliver this view.

What about general polarity - positive and negative mentions on a product without any detail? While this is absolutely possible, it is just as absolutely meaningless without the ability to drill down and find out what negative (or positive) things people are saying. Imagine getting a report with a spike in negative mentions for your drug and not being able to click through to understand the nature of the discussion.

The FDA is, most likely, waiting for a situation to respond to rather than proactively developing a policy about personal media monitoring and reporting. It will take some courageous leadership on the part of pharma to start some listening practices, just as it did with all other DTC communications. The risks may be worth it. Understanding patients more deeply will continue to be a competitive advantage for companies. And while a pharmaceutical company may not want to be the one to detect potential problems with their product via monitoring you can bet that patient advocacy groups, traditional media, or worse, trial lawyers, will do their own personal media monitoring.

For now, the model described above would give pharmaceutical marketers a valuable listening post into the great dialogue on the Web.

Engaging Dialogue is both listening and engaging. Once we have a way to listen then the fun starts. How can healthcare companies get involved with patients and professionals in a meaningful way in the new digital influence space? Is it starting a blog? Reaching out to patient bloggers for their opinions? Producing podcasts? Creating a relevant viral campaign that generates awareness about something new?

Personal media, the increasing power of search and microcasting (e.g., podcasting) are each contributing to a huge shift in how consumers get healthcare information and build relationships with brands.

Personal media (i.e., user generated media, consumer generated media) is all around us now. It's those blogs, the wikis, the message boards, the photoblogs at Flickr, even the garage-style videos on YouTube. Tools have simplified enough that we are all content creators now - instantly. It's a crazy soup of different points of view many with their own little audiences. And the size of a blog's (or a podcast's) audience can be deceiving. Size may not matter. The strength of the bond based upon trust and relevance is what matters. Podcasts are a simpler animal. They are canned content. A pharmaceutical marketer can create a program and send it through the legal department gauntlet and still end up with a program that can be distributed. Blogs require a back-and-forth dialogue to work.