I’m not big on tooting my own horn. But I can’t pass up the opportunity to publicize something that has been this important a part of my professional life coming to fruition.
I had the great privilege of working on this project for nearly two years. In addition to getting to work on a product that provides a novel method of treating a public health condition affecting millions of U.S. children each year, I got to work with terrific people who are some of the best around at what they do. I learned a lot from them and enjoyed working with them. Some of the people there spent nearly five years working to bring about this day – admittedly far less than the average time it takes to get a new drug through the entire R&D and FDA approval processes, but still a very long period of time. While larger pharmaceutical companies do this frequently, it’s quite a feat for a company that had 10 employees.
I’m very happy for them that they got to see this dream come to fruition.
While most of us (myself included) were preoccupied with our holiday celebrations, the FDA quietly released a Social Media guidance.
Sort of, anyway.
Ad Age‘s Rich Thomaselli reported last Friday that the FDA announced new Social Media marketing guidelines for pharmaceutical companies. But the document, titled “Guidance for Industry Responding to Unsolicited Requests for Off-Label Information About Prescription Drugs and Medical Devices,” only covers the discussion of off-label information.
For that reason alone, it falls far short of what the pharmaceutical industry not only was looking for, but needs.
“What everybody was expecting was actual guidelines around social media,” Jim Dayton, senior director of emerging media for Overland Park, Kan.-based InTouch Solutions, a pharma-centric digital-marketing agency, told Ad Age.
“I still think it’s monumental,” he added. “The FDA finally addressed the digital channel in a specific way by mentioning Twitter and YouTube in the document, and those have never been mentioned before. But this is an industry that wants specific instructions and rules, and that didn’t happen here.”
The document provides pharma companies with instructions for responding to consumers who use Social Media to ask about potential off-label uses for prescription drugs. A thorough, complete Social Media guidance – the kind the FDA held a public hearing more than two years ago to develop – would have been far more encompassing. Perhaps it’s no wonder then that the FDA released these guidelines during the Holidays (when they’re less likely to get noticed) and did so without even a press release.
“We understand the level of interest and wanted to get out what we had available to provide guidance,” FDA spokeswoman Karen Mahoney told Ad Age. She also added that this was just “the first of multiple planned guidances that respond to testimony and comments from the Part 15 public hearing that FDA held in November 2009.”
But when will those guidances come? And why does it have to be done piecemeal? This is all the FDA could get done in 2+ years?
It’s hard to believe, but another year is almost over. Christmas is only a few days a way, and a week after that, we’ll flip the calendar to 2012.
What will happen in the year to come in communication? In healthcare? In public relations? What new technology (or technologies) will emerge? Which existing technologies will be relegated to the dustbin of history, like coin-operated pay phones? What great advances will happen in healthcare and healthcare delivery? Which organization will build a strong foundation for years to come with strong, carefully planned and executed public relations efforts? Which organizations will be tarnished by bungling their public relations, particularly in a crisis situation?
We can ask those questions at this time every year. But here are some unique ones to think about as 2011 comes to a close:
1. Will Google+ seriously challenge Facebook? I was not impressed with it when I first got on, and I still use it only rarely. But it does appear to slowly be catching on. Will it become real competition for Facebook in 2012?
2. Will organizations reevaluate and improve their crisis communication plans? We saw the tattoo scandal at Ohio State and the horrible sexual molestation scandal at Penn State – they were just two examples this year of poor crisis PR. It’s an area to which many organizations do not devote sufficient resources or planning, and they can and have paid a huge price for that. Hopefully this year’s prominent crisis PR disasters taught them a lesson.
3. Will more pharmaceutical companies get serious about social media, even with no FDA guidance on the horizon? One of my favorite reads in the area of pharmaceutical marketing – Rich Meyer’s World of DTC Marketing blog – praised Sanofi’s “Why Insulin?” Social Media campaign as an example of how pharma companies can creatively and effectively use Social Media while not running afoul of the FDA. With no specific FDA guidance likely to come anytime soon, pharma companies can and should learn from Sanofi’s example. Will they? The cutbacks to marketing that many pharma companies made this year won’t help any.
4. Which Presidential candidate will do the best job crafting and selling his/her story? Next year will be a presidential election year (the Iowa Caucus is on Jan. 3!). Which candidate will put forth the best story? Which candidate will be the most effective at selling that story? And how much of an impact will the stories told by PACs and outside groups – who were greatly enabled by last year’s Citizens United ruling by the Supreme Court – have on the election? While I do find the partisan bickering in Washington to be tiresome, I do find campaigns themselves to be fascinating, and the upcoming election will definitely be fascinating, no matter which side you want to win.
That’s all for me in 2011. It’s been an interesting year for me in many ways – finishing my masters degree, helping build a start-up pharmaceutical company into a tangible product that could attract a merger with a major pharmaceutical company and now looking for the next opportunity. I leave you with what, in my opinion, is an underrated holiday song from an underrated movie. Happy Holidays, and all the best for 2012.
One of the blogs I have feeding into my RSS Reader in Outlook is Phil Baumann’s “Health is Social” blog. In his latest post, he makes the argument that the best hospitals enable customers to provide negative feedback.
I would venture to say that this same argument can be made for businesses in most or even all industries, not just hospitals.
Nobody likes negative feedback. Nobody likes being told that they’re bad or doing something wrong. But such feedback can be very valuable as well. You can learn about your mistakes and flaws and (hopefully!) fix them before they become more costly. And businesses can learn about how to adapt their product or service offering to better serve its customers.
The ability to receive and harvest that feedback is the greatest benefit of Social Media. Previously, the only way businesses could get steady feedback from customers was from watching whether their sales increased or decreased, by which point the problem was costing the business money. And even then you might not ever know what the problem really was.
The pharmaceutical industry has been perhaps the most hesitant to embrace Social Media, partly because of the lack of guidance, and also partly due to its fear of patients sharing adverse events that, even if they had nothing to do with the drug itself, could still convict the company in the court of public opinion (see my earlier blog post on this subject). But even that feedback can be beneficial. If nothing else, it could provide more insight as to who their customers are, where they are and what they do, allowing the company to refine its marketing strategies and tactics. This knowledge could even identify a new therapeutic area might want to investigate.
It never feels good to get criticized. But it is often the best thing that can happen to us. When the news is good, we are more tempted to ignore the areas still needing improvement. But negative feedback allows us – and businesses – to confront our shortcomings and fix them.
The Pink Sheet is a newsletter on the pharmaceutical industry read by many drug manufacturers. One recent issue had a report discussing the impact of Social Media, such as Facebook, on the design and execution of clinical trials.
Clinical trials, in particular the all-important Phase 3 Pivotal trials, cost many millions of dollars to execute. They are designed meticulously, especially when it comes to blinding and randomization controls. Study subjects can’t know whether they took the study drug, the placebo (or, if applicable, the comparative drug) until after the trial is completed. If they did, they might not react naturally or adhere to the study protocol, and the trial results could be compromised.
Derrick Gingery reports:
Craig Lipset, Pfizer senior director in clinical research, said patients are using chat rooms and forums directed at specific diseases, in some cases talking about the clinical trials in which they are participating and their experiences with the study drugs. The online talk could threaten a trial’s blinding and randomization, especially as patients are more able to interact with other trial participants, he noted.
At the same time, as Lipset says later in the story, asking clinical trial subjects to refrain from using Social Media is not realistic. Recruiting subjects for clinical trials and getting them to follow existing protocols is hard enough as it is. So trial sponsors and investigators need to account for these tools in designing clinical trials.
At the same time, researchers and pharmaceutical companies can also use Social Media to their advantage. While comments on a Facebook page or an internet message board are not statistically reliable or a substitute for the FDA’s adverse events reporting guidelines, they can provide hints of problems before they become catastrophic public relations disasters. On a more positive note, sponsors can, as Gingery reports, tap into social media to recruit subjects for clinical trials.
According to the study, less than 20% of the advertisements studied were completely compliant with FDA regulations. In addition, nearly half of the 89 advertisements from November 2008 issues of leading U.S. biomedical journals were non-compliant with at least one of the FDA’s descriptions of bias and a third were found to be possibly non-compliant due to incomplete information.
I admit that 89 advertisements isn’t a very large sample size. And determining whether something is FDA-compliant or not is a somewhat subjective process. But these figures suggest that the FDA may need to make its regulations of drug advertising simpler and easier to understand.
The large pharmaceutical companies have staffs dedicated to ensuring compliance with the regulations put forth and enforced by DDMAC, the FDA sub-agency that governs this area. Even the smaller companies take great care to stay in compliance. They thoroughly vet all advertising and other promotional materials. Then they vet them again, and even more times still, before they go out in the public domain. With fines of hundreds of thousands, if not millions, of dollars on the line, you don’t want to mess around with this.
Yet in spite of all that, a sizable majority of ads appear to be non-compliant. And this makes me wonder if the FDA should make its regulations clearer and more concise. I’m all for the FDA requiring drug ads to be responsible, accurate, truthful and fair and balanced. But all the regulations in the world do no good if companies can’t comply with them.
I believe that content should have what I call “the 4 Cs:” it should be clear, compelling, complete and concise. No one expects government regulations to be compelling (that’s not what regulation is for after all!). But it would only help drug manufacturers and marketers if those regulations were clear, complete and concise. Regulate what needs to be regulated, but make the regulations as clear and simple as possible.
First, a little context here: the pharmaceutical industry has been waiting for almost two years for the FDA to issue a guidance on the use of Social Media in the industry. Yet that guidance has not come and, as I noted here months ago, isn’t expected to come until 2013, if then. So pharmaceutical companies have slowly begun dipping their toes into the water, understandably moving very carefully due to their uncertainty over how the FDA’s extensive and complicated drug advertising and marketing rules apply to these new communication tools.
One aspect of Social Media that they have great concern about is user commenting. The FDA has very specific rules regarding the reporting of adverse events, and those rules don’t include posting those tales in a public forum like a Facebook fan page. In addition, like any business, pharmaceutical companies are very protective of their reputation and don’t want one nasty, ill-informed comment to jeopardize a product that they have spent hundreds of million dollars and many years researching, developing, testing and bringing through the FDA’s new drug approval process. So they moderate user comments carefully in the Facebook communities that they set up.
Now that Facebook is opening up user commenting on Facebook pages, several pharmaceutical companies are getting cold feet about engaging patients (ie, their customers) in this space. As Mack notes, Jannsen Pharmaceuticals is shutting down its ADHD Moms community, abandoning almost 24,000 followers. And Sanofi-Aventis is shutting down its “Voices” page, redirecting patients to its Sanofi US page.
Are these companies being prudent in response to Facebook’s changes? Are they overreacting? Or, as Mack suggests at the end of his piece, is this just a cover story for other reasons to shut down these communities?
Clinical trials are the backbone of the new drug development process. Without them, you can’t get FDA approval to market your drug. Pharmaceutical companies spend millions, of dollars designing, recruiting for and executing even a single clinical trial, and you need at least three, if not more, to get approval.
Instead of residing in or regularly visiting a research facility for the entire length of the trial, patients would administer the study drug (Detrol LA, Pfizer’s long-acting formulation of its overactive bladder treatment), as well as monitor and report the necessary vital signs and results, on their own. Pfizer’s project, which goes by the acronym “REMOTE,” is aimed at expanding access to clinical trials, and therefore diversifying the pool of participants, which currently is limited to whoever happens to live near the participating research facilities.
It’s a very interesting idea. And if it works, it could have some very positive results. In addition to improving access to clinical trials, it could save trial sponsors money by not having to compensate participants to repeatedly travel to the research facility.
But there are some very important questions that need to be answered:
How many drugs will this type of clinical trial be able to be used for? I imagine that drugs that need to be administered by a medical professional (such as intravenous chemotherapy drugs for cancer) won’t work for virtual clinical trials.
How do you go about training participants to correctly monitor and obtain the required data on their own?
Do they need to use exactly the same equipment to monitor and obtain vitals?
How do you protect the blinding and the confidentiality of the patient data when conducting a trial virtually? Blinding is vital to clinical trials. And patient data must be kept confidential to comply with HIPAA and FDA policy.
Would a virtual clinical trial shut out demographic groups that don’t have easy access to the necessary technology? How would this affect the reliability of the data?
I’ll be very interested to see how this project turns out. It could present a major revolution in the pharmaceutical research and development process. Or it could be yet another idea that sounds good in theory but doesn’t work in reality. We’ll see what happens.
I’m never surprised when government acts very slowly. But it has gotten beyond that now with the FDA’s pharmaceutical social media guidance. As Ogilvy’s Rohit Bhargava appropriately notes in the headline for this piece, the FDA just doesn’t appear to be that into providing guidance on social media.
Bhargava, citing an FDA document that outlines the agency’s priorities for 2011-2015, reports that a social media guidance, originally expected to be released by the end of last year, now likely won’t be released until at least 2013. Not for another two years. Even if the FDA actually releases a guidance that year (yeah, right), it will be almost four years after it held its public hearing on social media. It will also be almost 10 years after the debut of Facebook, seven years after the debut of Twitter, and even longer after message boards, blogs and ratings sites became available to the masses.
By then, the FDA will be way behind the times on this technology.
Pharmaceutical companies should probably give up waiting for FDA guidance at this point, if they haven’t already. It’s clear that they need to participate in social media. So they should just develop their social media plan and policies as best as they can using existing DDMAC guidelines. Use common sense and pay attention to when the FDA flags other pharmaceutical companies for violating DDMAC guidelines with social media, so you can learn from others’ mistakes.
It’s by no means an ideal way to go into social media. But the FDA clearly doesn’t care enough about this to publish a guidance anytime soon. Pharmaceutical companies still waiting can’t wait any longer. Just do the best you can with what you have.
As I have mentioned here before, one of the big (if not the biggest) reason why Pharma is hesitant to engage in social media is all of the regulation the FDA places on drug marketing. The FDA still hasn’t put out its long-promised social media guidance. And while pharma companies are slowly beginning to enter the social media waters, there are stumbles such as the recent one involving AstraZeneca’s “Take on Depression” discussion on Facebook. John Mack describes it in more detail on his blog, but to sum it up, discussion participants waiting for the application to load noticed that the URL http://www.seroquelfbdiscapp.com/ was also being accessed. That would be cross-marketing for Seroquel, AstraZeneca’s new anti-depression drug. This act is a violation of FDA guidelines.
The real interesting thing here, though, as Rich Meyer notes, is that this social media program was being executed by Edelman, one of the world’s largest PR firms. Some of the work for this program was also being outsourced to other individuals. Bad move on AstraZeneca’s part.
With all of the complex regulation involved in pharmaceutical marketing, social media programs need to be executed by the pharmaceutical companies themselves. They have the staff on site that thoroughly understands the FDA’s drug marketing regulations and what they allow and don’t allow. Even large agencies like Edelman may not have specialists in this area. Certainly smaller agencies may not have the expertise in this area. And when you don’t know what you’re doing with FDA-regulated marketing, you could find yourself getting a warning letter or a fine from Uncle Sam.
It’s one thing to have an outside agency help with designing your social media strategy. But once it is designed, it should be executed in-house. If you’re a major pharmaceutical company like AstraZeneca, there is no excuse for not doing this. If you’re a small company and absolutely don’t have the resources to dedicate someone on staff to this task, make sure that the agency you outsource it to knows FDA drug marketing regulations and how to comply with them. It may cost you a little more money now. But it could save you A LOT of money (in the form of FDA fines) later.
I am a native of Chicago, but have lived on the East Coast for almost 20 years. After spending nearly two years helping a start-up pharmaceutical company develop messaging and marketing strategy that ultimately led to a value-adding merger with Sanofi-Pasteur, I am now helping The AmeriHealth Mercy Family of Companies share its stories of improving access to the health care system.
In May 2011, I completed my Master's Degree in Communication Management from Temple University. My Master's Thesis was an examination of how physicians can use Social Media not only as a marketing tool, but as a means to improve patient outcomes. I also have a Bachelor's Degree in Journalism from Boston University and more than a decade of professional writing experience.
My related interests are in messaging and framing in politics and in the use of social media platforms (including blogs similar to this one) by the healthcare industry to engage patients directly, drive them to healthcare providers and make them more educated consumers when they do so. I find this field particularly rewarding and hope to remain in it.
Thank you for visiting On Message. Unless otherwise indicated, all opinions contained here are those of the blog author and do not reflect those of any other organization or individual.
All images contained here are used under the Fair Use doctrine of United States Copyright Law.
All company logos and other trademarked items displayed here are the registered trademarks of the indicated entities. I do not claim to own those trademarks.
All information here is subject to change.
I’m not big on tooting my own horn. But I can’t pass up the opportunity to publicize something that has been this important a part of my professional life coming to fruition.
On Message 