Following last week's FDA hearings, we know we probably won't hear guidance from the FDA for a year or so. In the interim, we must continue to rely on past experience, existing DDMAC guidance, and what we heard from those who testified.

Edelman has long counseled companies that health is a business imperative and that they must engage proactively, transparently, and in real time with all stakeholders about health and wellness. We recognize the challenges manufacturers have faced in the past decade in engaging online because of the lack of regulatory guidance. And we believe this hearing will ultimately—though perhaps not immediately—make a significant difference in the way manufacturers communicate online.

We have created a report which summarizes the issues and provides guidance to manufacturers on how to engage in online communications now. We believe it is imperative that companies engage with their customers and stakeholders, not postpone engagement until final guidance is received from the FDA.

We continue to work on our written testimony and encourage others to do so as well. As a reminder, the FDA is accepting these through February 28, 2010.