Monday, October 31, 2011

In Rejecting Proposal, EU Dashes Drugmakers’ Hopes of Having a Voice

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Casey Ferrell is a research analyst at Cutting Edge Information. He will be guest blogging at IIR’s upcoming ePharma Summit 2012 (February 6-8, 2012 in New York City). You can find him on Twitter or over on his company’s blog.

Three years ago, there was a glimmer of hope for drugmakers in the EU to be able to publish information about their products. But in early October the European Commission, the executive arm of the EU, flexed its muscles and dashed any hope that the governing body would relax the rules restricting pharma’s contact with consumers.

In 2008, the European Union’s Pharmaceutical Forum introduced a proposal to reform marketing rules and effectively allow pharma companies in Europe to circumvent the existing ban on DTC advertising. In the face of ensuing backlash from consumer protection agencies and patient and physician advocacy groups, the Commission eschewed it in favor of a milder one that would allow drugmakers to communicate to the general public in written form and on the Internet, primarily in selected media such as health publications.

Earlier this summer, the Commission said it would review the proposal. In the three years since the proposal was brought up for consideration, turnover on the Commission and a shift in the responsibility for pharma policy from the Commission’s industry division to its health division helped create a less receptive environment for the “deregulation” of pharma marketing and tempered any optimism for change.

However, the final ruling went beyond rejecting the original proposal and ensured that pharma companies would not be allowed to disseminate information about drugs and their indications beyond a narrow set of circumstances. In other words, the already restrictive regulatory environment on pharmaceutical communications got even more so. Lynne Taylor of PharmaTimes described the tougher measures:

They also propose that:

  • only "certain" information on prescription drugs would be permitted, such as that on the label and on packaging leaflets, plus information concerning prices, clinical trials or instructions for use;
  • information on prescription-only drugs would be permitted through limited channels of communication, such as officially-registered internet websites or printed information made available when specifically requested by consumers. Publication in general print media would not be allowed;
  • the information must fulfill recognized quality criteria — it must, for example: be unbiased; meet the needs and expectations of patients; be evidence-based, factually correct and not misleading: and be understandable; and
  • as a general principle, information which has not previously been approved will need to be verified by the competent authorities prior to dissemination.

Although the development is not surprising to most in the industry, there was a hope that the Commission would allow the previous proposal to stand, giving pharma an opportunity to provide information about their products in general media. The industry has long claimed that they need the latitude to provide reliable, accurate information about their drugs to counteract the abundance of misinformation available. Ben Comer in his PharmExecBlog quoted Ian Read, Pfizer’s president and CEO, as describing DTC advertising a “fundamental right in the U.S.,” and its absence “leads to ignorance and the inability to judge.”

The EU is certainly not the US, but do pharma companies have a “right” to promote their products to consumers? Would allowing pharma companies to communicate more freely in Europe lead to better information for consumers and better health outcomes? Or is it a slippery slope that leads to DTC “in disguise?” Perhaps there is a middle ground short of DTC but that affords pharma something more than zero communication. What are your thoughts?

Thursday, October 27, 2011

The 2012 ePharma Summit Brochure is Now Available!

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Get all the details on the largest and most respected digital marketing event in the life sciences industry. Download the full ePharma brochure to see all the new sessions, speakers and formats we've introduced to make this year's ePharma Summit the best ever. The ePharma Summit will be taking place February 6-8, 2012 in New York City.

Highlights include:
  • More case studies than any other event with presentations from: J&J, Janssen, BMS, Pfizer, Sanofi, Galderma, Biogen Idec and more...
  • The best workshops from the perennial favorite eMarketing University for Brand Managers, to Digital Marketing Around the World, to the new Medical Legal & Regulatory Marketing Policy Summit
  • Keynotes from top minds in the industry including:
  • Charlotte McKines, Global VP, Marketing Communications and Channel Strategies, Merck & Co. Inc.
  • Kevin Kelly, Author, What Technology Wants, Founder & Senior Maverick, Wired Magazine
  • Robert Safian, Editor & Managing Director, Fast Company
  • Andy Smith, Author, The Dragonfly Effect
  • Donald Casey, Chief Executive Officer, Board Member, West Wireless Health
  • 75% pharma speaker faculty to ensure you learn from those who've been there and done it


Don’t forget, when you register using code XP1706BLOG for 10% off the earlybird pricing! If you have any questions, feel free to email jpereira@iirusa.com.

Mobile Focused on Commercialization (at the Expense of Clinical Development Opportunities?)

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Casey Ferrell is a research analyst at Cutting Edge Information. He will be guest blogging at IIR’s upcoming ePharma Summit 2012 (February 6-8, 2012 in New York City). You can find him on Twitter or over on his company’s blog.


Smartphones will become the standard device consumers will use to connect to friends, the internet and the world at large, and that future is nearly at hand. The share of smartphones as a proportion of overall device sales has increased to 29% for phone purchasers in the first six months of last year, and 45% of respondents to a Nielsen survey indicated that their next device will be a smartphone. Predictions based on current growth rates — much of which is fueled by emerging markets — put the number of smartphones in use by 2014 at more than 1.5 billion.

The majority of smartphone owners have downloaded and used mobile applications, or apps. According to research, iPhone users have the most installed apps, with an average of 37 per device, whereas Android users have 22. These figures are significantly higher than those from just a year ago, and apps are poised to proliferate in lockstep with the growth of smartphone usage. But a problem with apps is usage retention. An oft-mentioned factoid from the Digital Pharma East conference this week pointed out that only 5% of people still use an app one month after downloading it.

Pharmaceutical companies are aware of the potential for mobile applications and have already built a robust array of offerings. More than 15,000 apps are available in the Health/Fitness and Medical categories for the iPhone alone. Research by the California HealthCare Foundation found that most healthcare-related apps are related to exercise, stress management, diet and medical reference. Close to three-quarters of apps are geared for consumer — or patient — use. The rest are aimed at physicians, pharmacists and other healthcare professionals. To wit, one company alone offers more than 600 medical apps for physicians, nurses, med students and institutions, focusing on delivering answers to clinical questions in more than 35 specialty areas. Apps for clinicians hold the potential to revolutionize the way in which healthcare is administered. There are digital imaging apps for ECGs and radiological procedures; there are apps that improve emergency room efficiency; and there are apps designed to improve patient-physician interaction, including some that facilitate remote consultations.

But if usage retention rates continue to hover in the single digits, the industry will soon realize the market is saturated with one-off mobile health apps and that despite the low cost of developing them, there is even less ROI than it first envisioned. Research from a report I recently led shows the industry sees commercialization as the phase ripest for mobile technology.
The emphasis on product commercialization is evident in this graphic based on my research. It shows survey respondents’ average ratings of mobile technology as a support tool for each development phase on a scale of 1 to 10. In early development phases, mobile ranked lowest at an average of 3.6, and the average climbed steadily through the development phases to a high of 7.4 for mature products.

I would argue that given the gold rush to develop apps for the commercialized marketplace, there is an opportunity for the industry to shift its focus and look for innovative ways to use mobile technology to improve clinical development. From streamlining trial data collection and analysis to connecting potential trial patients to investigators, the clinical development space is an opportunity for pharma companies do differentiate themselves from the pack, find more value for their mobile investment and improve pipeline challenges that impact bottom lines. In other words, while developing consumer apps may be the trendy approach, other stakeholders, like trial patients, physicians, investigators and clinical development staff, stand to benefit if more mobile technologies were aimed at them.

Wednesday, October 26, 2011

Enough with the Spamming, People.

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Today's guest post comes from at closerlook, inc. He blogs at digital-pharma.tumblr.com and pretty much lives on Twitter (@digital_pharma) if you'd like to reach out.


My biggest marketing pet peeve is when marketers forget to behave like human beings and just behave like marketers. Case in point: marketers who treat their audience like morons, but get grumpy when treated like a moron by other marketers.

Didn't we all learn that while everyone’s experience is individual and unique, the first way to evaluate a marketing idea is to ask yourself, “how would I respond to this?”

To that end, I am now putting you pharma marketers on notice: no more spam. You hate spam. I hate spam. And our audience hates spam.
And yet, there you go, sending emails every X days, pretending that you have something interesting and useful to say, but really all you’re doing is trying to remind your audience that you and your brand aren't dead.

Sound mean? Bear in mind that I'm giving you the benefit of the doubt by not assuming that you are emailing every X days simply because you charge your client by the piece. No, I'm gonna assume you're not a jerk.

So anyway, no more spam. Agreed? Good.

Oh, you're worried that the notion that “absence makes the heart grow fonder” is a fallacy? You’re worried that without regular emails reminding them that your brand is an effective solution for XYZ, HCPs are going to forget all about you and just prescribe baby aspirin, or something? Okay. Let's pretend you don't spend money on ads and conference promotions and websites and eDetails and reps and giveaways and all those other things. Let's pretend email is the only way to contact your audience. How do you contact them and not spam them?

There are two parts to converting your email system from spam to steak. Part one, upgrade your content. No more junk. No more content that you wouldn't be thrilled to get yourself. Remember, your targets get the same emails from dozens of other brands, so don't feel like you need to send an email for every little thing.

But as a brand, you may not have a lot of content. So what do you do? Since your brand is excellent at treating disease state X, I bet your brand has a lot of knowledge about disease state X, right? I bet there's a chance that you have a Google Alert for any news about brand state X. Maybe you even subscribe to a bunch of blogs about that disease state (and if you don't, why don't you take a moment and do that now. You’ll thank me later). That there is a lot of content you can share. And you are curating it, even if it is only for yourself or an internal team. Here’s my suggestion: let it out. Become your target’s one-stop shop for news about disease state X. Send them an email every X days with links to all the biggest stories online about the disease state (it's not all about you, you know). Wrap that curated content with a simple message that your brand cares about keeping health care professionals up to date about the disease state. That's the kind of content they will be glad to get, and perhaps even share.

Part two, embrace your segments. Are you just sending your entire target list the same emails? Shame on you. Are you segmenting? Good. Tell the truth: are your segments based on year-old data, or are you monitoring the data and adjusting your segment populations accordingly? How long would it really take a target to move from your “unlikely target” segment to “power prescriber” segment if they started prescribing like crazy today? How long would it take you to notice and react?

Are you making adjustments based on behavior? For example, do you treat the target who opens five of your emails in a row the same as the target who hasn't opened an email of yours since 2009?
If you treat all your targets the same, they will treat your messaging like spam and toss it out. The fastest way to stop being perceived as a spammer by your targets is to stop sending spam: treat different doctors differently and give them something they truly want to read.

Friday, October 21, 2011

Top 50 iPad Apps for Doctors

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No matter where you were or what you were doing this week, at some point you heard, read, or viewed information about the new iPhone 4S. (Especially if you’re a blackberry user!) A new camera, a dual-core a5 chip, and who is this Siri? I think it’s safe to say there’s a lot that can be achieved from this tiny device. With new technology, comes new opportunities, especially in the APP world. There are apps for virtually everything, from drug information to HIPPA compliance, what do you hope to see for the future?

With the overwhelming amount of applications available every day, it can sometimes be difficult to find the exact one you’re looking for, and in the healthcare industry, time and precision are everything. We’ve found a list of the Top 50 iPad apps For Doctors - here. Which ones do you find to be the most useful? How do you think this will affect the Pharma world?

At ePharma Summit 2012, we will feature a Future Trends in Mobile track to look further into this topic. The ePharma Summit will take place February 6-8, 2012 in New York City. For more information, visit our webpage. Use code XP1706BLOG when you register to save 10% off the current rate.

Tuesday, October 18, 2011

The Google-sized Hole in your Marketing Strategy

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Today's guest post comes from at closerlook, inc. He blogs at digital-pharma.tumblr.com and pretty much lives on Twitter (@digital_pharma) if you'd like to reach out.


What if I told you that there’s a hole in your marketing strategy? It could be a small hole or a big hole, but I’m betting it’s there nonetheless.

When building your marketing strategy, you start by making HCPs aware of your brand, probably using a combination of rep visits, ads, commercials, conference appearances, microsites, tchotchkes, giveaways, honorariums, and videos. Maybe you use all of them, maybe just a few of them, but they are stimuli designed to do one thing: make the target aware of your brand.

Once aware of the brand, you hope and anticipate that with some persuasion, HCPs will start prescribing your brand. They are selecting your brand in the same way people select which soda they want to drink or what car they want to buy.

Finally, the target evaluates the outcome of choosing your brand. Did it do what they expected it to do? Were there outweighing side effects? Would the HCP prescribe it again, and if so, under what circumstances?

Stimulate, select, then evaluate. That’s the basic gist of it. Maybe you’ve built in a persuasion step before the selection step. This is smart because every HCP is inundated with messages about brands, some of which may compete with yours. You need to persuade your audience that your brand is some combination of effective, safe, useful and inexpensive.

So where’s the hole? What’s missing is a step between creating brand awareness and HCP’s interest in prescribing the brand.

Let’s pretend you were watching television 18 months ago and you learned about an amazing new product called an iPad (stimulus). What do you do? Go and buy one? Well, if’s you’re the kind of person who can spend $500 (minimum) on something you don’t know much about, here’s to you! But the rest of us did a little research before we bought (or didn’t).

There was a stage when you wanted to learn more about the iPad, wasn’t there? You didn’t only go to the Apple site (though I’m betting you did spend some time there), you went and looked at reviews, both official and unofficial. You read some blog posts about other people’s interest or disinterest in the iPad (and why). Maybe you tried to see if anyone was offering it for sale at a discounted price, or what kinds of options you’d have for covers and cases. Did it work with a stylus if you wanted it to? How hard was it to type on? Would you need the 3G version? How much space would you reasonably expect to need? When would apps be available? Would they be more expensive than iPhone apps? You had a lot of questions, and you looked at a lot of sites to answer them.

According to Jim Lecinski in his book ZMOT: the Zero Moment of Truth, the average shopper visits 10.4 websites before making a decision to buy or not to buy. Even if you argue that HCPs don’t do that much research on your brands (and it’s an argument I’m only allowing for the sake of my point), let’s split the number in half. That means that before your target actually decides to prescribe, they look at five sites, and I’m guessing you don’t have five websites about your brand. That means that your targets are looking at other sites about you to make their decision.

It’s like owning a store and knowing that your shoppers have to go to another location (or another store!) before buying from you. If that was something you knew was happening, what would you do about it?

On the face of it, this isn’t a revelation. Or it shouldn’t be. But it should make the hole in your marketing strategy clear. If your target is going to go to at least four sites that aren’t yours to learn and make decisions about your brand, should you just let them go?

Now, we all know you are limited to what you can say on your website. But so are your competitors. And HCPs know that. However, your targets will be thrilled when you help them find more information about your brand off-site. Send them to forums where HCPs talk about your brand, or social networking sites devoted to the disease state. Point out where you keep your own research on the brand’s efficacy and anywhere else good research can be found.

Don’t worry if the opinions on these sites aren’t 100% positive (There’s no such thing as a brand with 100% satisfaction: even aspirin has some drawbacks and detractors,) as “opening the kimono” and not hiding your imperfections increases your authenticity with your targets. It shows that you are a partner in health, not “just a vendor.”

Remember that HCPs are going to find all your flaws with just a few clicks. Do you want them to think you are hiding them, or that you’re trying to increase awareness about the pros and cons of your brand?

Thursday, October 13, 2011

The Five Steps to CRM Enlightenment

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Today's guest post comes from at closerlook, inc. He blogs at digital-pharma.tumblr.com and pretty much lives on Twitter (@digital_pharma) if you'd like to reach out.

On the path from communication chaos to marketing message perfection, there are five steps. These five steps take businesses further into a world where each email is better targeted, giving it more opportunity to be heard, absorbed and acted upon.


Step One: What CRM? We’ve just got this list
We start our journey in a place most of us remember (if you don't remember, call up your predecessor on the golf course and ask him or her. They'll be able to tell you stories.) The beginning of email was the beginning of electronic communication and the realization that everyone, including doctors, had email addresses. These were the bad old days, when any privateer could build a list of email addresses and peddle them to any and all who asked for them. Were they validated? De-duped? Non-bouncing? Active? Who knew! Everyone got paid on a per-email basis one way or another, so it didn't matter that metric tons of emails were disappearing into the ether(net) without a trace. Activity was enough.


Of course, this recklessness eventually spawned spam laws that made it illegal to simply buy lists and spam them. Thankfully, those days are gone.

Step Two: Managed Lists
This leads us to the next step in email’s evolution. You had lists, now you needed a way to manage them. Validation, opt-in and unsubscribes were the watchwords of the day. The list you had was managed. You asked people to join it, you may have even given them a good reason to join it, and every one on that list knew that at any time, they could leave. This power shift caused marketers to think more in terms of how often they could touch a target before they got annoyed and left and less in terms of sheer volume.

Step Three: Understanding the Aggregate
The next step is to measure the aggregate audience. Up until this point, you just had email addresses. Marketers had no name, geographic information, or specialty information, let alone school, practice type, or activity with the brand attached to the email address. Before now, if the target was on your list, and that target went to a conference and signed up for something, there was a good chance that they’d start getting multiple emails because the managed lists were being managed by multiple departments.

This step enables you to integrate the silos and examine all the data in the aggregate. Now you can see how many subscribers you have. You can how many people click on the emails. And you can report those numbers upwards, as if they mean much.

Sadly, this is where a great majority of us are, halfway along the path. Let us see what the next steps are and what they can achieve for us.


Step Four: Segmentation
The fourth step is to take that data and break it up into segments. This closes the loop between what you send and what you get back. You can see that doctors in, say, Ohio are opening and clicking at a higher rate than any other state. Or that in August, all the oncologists on your list don't click much at all. Why is that? A little investigation might show you that your brand is being mentioned in the press locally, or that there’s a big oncology conference that month that disrupts message flows. Hmmm... Once you know that, what could you start doing differently? Maybe sending a special message to targets in Ohio that mention the local media coverage with a call to action tied to it? Or a message to oncologists at the beginning of August, wishing everyone safe travels and a call to action to visit your booth at the conference?

When you achieve step four, you have just enough information to be able to understand groups and take action. This is where we marketers strive to be. The purpose of managing lists and collecting data is to be able to recall and leverage that data to move the needle, right? This is how that happens.

Step Five: Everyone Is Special
The final step takes that idea further. Further, you say? Yes. Instead of interacting with your targets as groups, what if you could interact with them on an individual level?
How is that possible, you say, when you have a hundred thousand names on a list? How can you interact with a hundred thousand people on an individual level? Well, you start by buying them coffee.

Not really. You start by building a matrix. Think of all the different things that might change one of your target’s perspectives. All the stuff you already know, like specialty and location, school and practice type. Then add in the activity data, like how often they prescribe your brand, how often they click on the emails, if they ever go to conferences, etc. One day, you’ll be able to bake in more attitudinal data, like how subscribers responded to a survey, or in a poll on your eDetail, or if they have connected to any of the social networks your brand listens to.

Take all those data points and build a matrix to help you understand why a given target might or might not prescribe your brand. If you understand their underlying belief patterns, you’ll understand why they are prescribing or not prescribing. From there, you can tailor messages that challenge those beliefs, stimulate new ideas, or encourage the target to prescribe your brand.

You're not talking to them one-on-one so much as you are building an abstracted layer between you and them that will do most of the work for you. In some circles, this is called psycho-demographics. The ability to create custom types that are far stronger at predicting the likelihood of prescribing than straight deciles. And connecting your CRM to these types allows you to fine-tune the messages you send to each type, so that no market is ignored. Even targets who have never prescribed your brand can be sent attitude-changing messages rather than selling messages to help move them up the acceptance ladder.

This is the Zen of CRM. The path is long, but rewards lay at the end of it.

Wednesday, October 12, 2011

Some Pharma look to their Facebook pages as a forum for dialogue

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While many Pharma companies shut their Facebook pages down, as they were forced to allow discussion on all their pages, others kept their Facebook pages open.  While fear of having to report any  incidences to the FDA, others saw the forum as an opportunity for discussion and a place to build a community for those who their pages are targeted at.

Lauren Folino at MM&M points to the fact with this open dialogue, moderation is needed.  Many are challenged by the time it takes to fully moderate the forums.  Others outsource their moderation.    Others choose to outsource their moderation. Boehringer Ingelheim is one of the companies who moderates their own forums.

Do you think Pharma stands to benefit more from the use of social media?  How much of a challenge is it to keep these mediums fully moderated and is it worth the benefit?

Tuesday, October 4, 2011

Is Pharma Addicted to E-mail?

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Today's guest post comes from at closerlook, inc. He blogs at digital-pharma.tumblr.com and pretty much lives on Twitter (@digital_pharma) if you'd like to reach out.

How often is too often to send an e-mail to someone? What's the magic number of e-mails per day/week/month that defines the border between Helpful Communication and everyone's nemesis, Spamistan?

That magic number is three.

Oh, was that not enough information for you? Oh, okay, I'll spell it out.

First of all, let's all embrace the idea that one person’s spam is another person’s (um, your and my) job. Yes, there are messages that are always spam, like the ads for Canadian Viagra, Lovely Ladies Looking for Me (ladies, do you get spam about hunky guys who are new in town? Just wondering), Foreign Exchange Investing, and Re-growing Hair (huh... I just realized that a huge percentage of the spam we get is tangentially pharma related. I wonder what that means? Anyway...).

But if these messages are spam for everyone, no one would ever make a dime from those e-mails. And if there wasn't any money in it, no one would be spending money on sending them. Thus, there are people out there who believe that that pill is their long-lost answer to male pattern baldness. Even Viagra spam is someone’s idea of an interesting message.

So there’s no such thing as perfect spam (i.e. an e-mail message that has no value to anyone ever). That also means that there’s no such thing as a message that’s 100 percent interesting to everyone. Even e-mails I normally look forward to getting might feel like spam if I don't have the money to spend on them today.

So everything is on a “spam spectrum,” as it were. A good marketer’s job is to position all the elements of an e-mail campaign to make the message feel relevant and useful to all the recipients (relevant and useful being the opposite of spam). This involves designing the e-mail to be readable, even if images are turned off, removing as many spam-flagging words as possible, picking a time to send when it won't get lumped in with the rest of the early-morning or lunch-time spam waves, and doing the technical work to make sure e-mail servers don't think it's been mass-mailed from Russia.

And good marketers will make sure that the content of the e-mails is actually useful to as many people as possible.

I know it's a given that we think that HCPs need to be sent an e-mail every X days or else they’ll forget about our brands. We think that if HCPs don't see our logo every day, they’ll assume the brand is gone and never prescribe it again.

I'd like to challenge that assumption. I believe the if we sent an HCP five e-mails in a row, say, once a week or so, to explain the value of our brand, to show off its method of action, how it's different, when to prescribe it, its safety record, you know, the entirety of our brand’s value proposition, we should stop and get out of our own way. Thereafter, just send news like new research, label changes, formulary changes, etc. Oh, and maybe an occasional “thanks.” And that's it.

As we get closer to better managed and used CRM systems we should be able to do this very easily. But instead, we take a few dozen messages and send them out every X number of days like clockwork. It doesn't matter if there's something useful or relevant to HCPs for us to send, we just send it because our instinct says a semi-worthless message is better than no message at all.

Which brings us back to the magic number three. No, what I'm about to say has not yet been tested. I'm basing it off my experience and some basic sociology and psychology. So here it is.

When your audience gets the third message in a row that it doesn’t see value and relevance in, they reach for the spam button.

Of course, the issue is that what’s valuable to one person (male-pattern baldness cures) is worthless to many others. So a marketer’s goal is to build more and better high-value e-mails, ones that don't invite spam complaints.

So you can see why I’m intrigued by the idea of short-course e-mail campaigns instead of year-long clockwork campaigns. By distilling your best content into a five-message run, you might have a more powerful campaign on your hands – one that actually costs less because you've stopped building and sending fluffy content that serves no purpose other than to count as a “touch” in your (okay, our) metrics. You're able to focus on building a handful of killer messages instead of thinking up ways to spread your messages out even further. Remember, Apple built the capping to remake itself as a home-computing expert with a single ad that only ran once. Quality, not quantity, will put your message into your audience’s mind.

Monday, October 3, 2011

Pharma, Regulate Thyself!

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By Casey Ferrell

Research Analyst, Cutting Edge Information

Perhaps those who clamor for guidance are misguided. The well-documented lamentations by pharma, in which the regulatory vacuum surrounding social media is blamed for the industry’s inertia and inaction, indicate a pervading wait-and-see attitude that stunts the industry’s ability to keep up with the digital revolution. There is a sense among ePharma thought leaders that the FDA’s long-awaited guidance on the Internet and social media will define the digital marketing landscape and clear up what can and cannot be done. And then we’ll get on with it. None other than Pfizer’s Ray Kerins, VP of external affairs and worldwide communications and VIP in pharma social media circles, said at a recent conference, “We all want guidance. We’re looking for it.”

But is that really the answer? Because according to fresh research by my firm, Cutting Edge Information, competing pluralities of respondents to a digital marketing survey think either FDA guidance is the key or that self-regulation is the way forward. When asked what they would rather see, industry insiders chose self-regulation almost as much as they chose an FDA informal guidance as the most desirable way forward for digital marketing in pharma.

A glance at the board of directors for the newly formed non-profit Digital Health Coalition and one finds the names of some heavy hitters from a broad spectrum of industry sectors, from pharma to agency, from search firms to physician and patient advocacy groups. The level of interest in the coalition’s mission — to develop a code of practice for digital marketing which all industry stakeholders can agree to and abide by — reveals an increasingly popular notion that waiting on regulatory guidance might not optimal. Not only has the FDA twice missed self-imposed deadlines for the guidance, creating a pervasive uncertainty about if and when it will follow through, but concerns abound about the breadth of the potential guidance. Will it tell us how to use individual platforms like Twitter and Facebook? Almost certainly not. Will it definitively determine who is liable when promotional content is shared (or altered) on third-party sites? Probably not. Will it actually provide the working model for acceptable digital marketing that is hoped for? Again, in doubt.

As the realization sinks in that an FDA intervention may not be the panacea that marketers are looking for, it’s clear the alternatives are limited. Individual companies can continue the status quo of feeling their way in the dark, only finding out they crossed a line they didn’t know was there after getting a Notice of Violation. Or, the industry as a whole can begin divesting in digital marketing as a channel, although its ubiquity and potential make this pretty implausible. Or, the industry can collaborate, as has been done in the U.K., and collectively define acceptable parameters for digital marketing based on existing regulations. No small task, admittedly, but better than the wait-and-see approach. In other words, perhaps the time to get on with it is now.