April 1, 2011 — Addressing a recent article in The New York Times, Sander A. Flaum, managing partner, Flaum Partners, and chairman of the Fordham Leadership Forum at the Fordham Graduate School of Business, writing in MedAdNews, refutes the author’s comments about the pharmaceuticals industry and discusses a federal research center proposed by the Obama Administration to help create new medicines. “When President Obama was citing the need for innovation in this country, it’s unfortunate that he didn’t acknowledge that in Pharma, we already have one of the world’s most innovative industries,” Flaum asserted.
Click here to read the full MedAdNews article
Obama Administration Says Legislation Would Provide “Firm Legal Foundation”
March 17, 2011 — Current industry self-regulation on digital tracking and marketing practices may not be enough to stave off legislation establishing a mandatory Do Not Track program, according to testimony and remarks made at a Senate Commerce, Science & Transportation Committee hearing held March 16 to discuss the state of online consumer privacy.
Although Committee Chairman John D. (Jay) Rockefeller IV (D-W.Va.) acknowledged in a statement that some members of industry have taken steps to address consumer privacy, he contended that voluntary programs are not yet sufficient to protect consumers.
“For too long, Congress has been asked to let self-regulation work. We’ve waited. And waited,” Rockefeller said. “And while we’ve waited, Americans have grown exposed. Self-regulation, by and large, has been a failed experiment.”
Significantly, Lawrence E. Strickling, assistant secretary for Communications and Information, National Telecommunications and Information Administration, U.S. Department of Commerce, told the Commerce Committee that the Obama Administration supports legislation in this area. “I can report today that the [Obama] Administration now recommends that Congress enact legislation to provide a firm legal foundation” to support online consumer privacy protection, Strickling said.
Coalition, 4A’s Support Digital Advertising Alliance
Despite these calls for new laws, the Coalition for Healthcare Communication continues to strongly support industry self-regulation, as a way to both honor consumer preference as well as avoid broad legislation. “Yesterday’s Senate hearings highlight every citizen’s interest in privacy, especially the need for digital health marketers to respect the choice of their customers,” said Coalition Executive Director John Kamp.
“That’s why the Coalition and the 4A’s have forged ahead with major industry partners to build a system where Web users know when they are being tracked and are allowed to opt out. Indeed, industry self-regulation is well ahead of the FTC and other government regulation efforts,” Kamp noted. “We must be wary of the FTC’s favorite Do Not Track program. While it’s popular in the telemarketing context, digital is different and the current proposal looks more like a sledge hammer than measured regulation.”
The 4A’s and the Digital Advertising Alliance issued the following statement in response to the Senate hearing:
“We strongly believe in protecting consumer privacy. It is not only the right thing to do, but it is good for business. Consumers should absolutely have a choice about whether they want to be tracked online. Efforts of the government are to be applauded, without a doubt, but online privacy and a robust, relevant online experience need not be mutually exclusive.
The interactive industry strongly supports consumer privacy and meaningful choice and is building the strongest self-regulatory program possible (http://www.aboutads.info) – one that empowers consumers to exercise control over their information online. This effort has been spearheaded by the American Association of Advertising Agencies, the Association of National Advertisers, the Interactive Advertising Bureau, and the Direct Marketing Association, and also includes the American Advertising Federation, the Network Advertising Initiative, and other leading industry associations that collectively represent all of the key elements of the Internet ecosystem.
We believe that this approach is meeting consumers’ privacy expectations today and will be equipped to evolve to continue to do so in the future. We will continue to work with all policymakers on these important issues.”
Industry Wants More Time, Not Legislation
Speaking on behalf of industry at the Senate hearing, John Montgomery, COO, North America, for GroupM Interaction, said that the Digital Advertising Alliance has indeed made progress, citing among other milestones a consumer education “Privacy Matters” campaign, the development of an Advertising Option Icon, the launch of the AboutAds.info Web site and consumer-facing opt-out page, and enforcement programs under the Direct Marketing Association and the Council of Better Business Bureaus.
Montgomery also stated that a self-regulation program will help consumer privacy protections evolve, because it can adjust to market circumstances in a flexible, efficient manner outside of the legislative process. “One of the benefits of industry self-regulation is its ability to respond quickly to changes to technology and business practices,” he said.
For example, one of the hypothetical concerns being raised regarding information collected via behavioral advertising is that the data could be used at some point for employment, credit or healthcare eligibility. Although this is not current business practice, the self-regulatory program already is addressing those concerns “to clarify that this practice will never occur,” he added.
Further, Montgomery advised the Senate panel that it is important to avoid sending consumers a “mixed message” that could inhibit them from acting because it adds confusion to an already complex arena. “We have to ensure that there is a single standard,” he concluded. “Self-regulation creates the right framework for innovation and privacy.”
Commerce, FTC Weigh In
However, government speakers and several Senators pushed hard for both legislation and regulation. Strickling told the Senate panel that the Commerce Department has concluded, following consideration of comments received on its green paper, entitled Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework, that legislation – establishing a “consumer bill of rights” – should be enacted to support consumer privacy. Strickling said the Commerce Department is hoping to issue its final report on online consumer privacy this spring.
Federal Trade Commission (FTC) Chairman Jon Leibowitz stated that he is “agnostic” about whether industry adopts a robust, enforceable self-regulation mechanism or whether Congress acts to protect consumers through legislation, but he also stated that Do Not Track should not just be an “empty slogan.”
“I hope American businesses will step up their efforts,” Leibowitz told the Committee. He cited the work done to date by the Digital Advertising Alliance to develop “Self-regulatory Principles for Online Behavioral Advertising” as “promising,” but also added in his written testimony that these efforts “are still in the embryonic stage, and their effectiveness remains to be seen.”
Representing the American Civil Liberties Union, Legislative Counsel Chris Calabrese told the Committee that the ACLU rejects any approach that relies solely on self-regulation and fully supports legislation. “Companies’ promises are important, but not enough,” he said.
At the conclusion of hearing, Sen. John Kerry (D-Mass.) stated that the Committee “would continue a thoughtful process” on the matter. Kerry indicated that he is currently working on a bill to establish a “commercial privacy bill of rights.”
March 11, 2011 — As the public debate over digital privacy continues, federal regulators on and off Capitol Hill are telling online marketers that now is the time to widely adopt strict self regulatory programs that enable Web users to opt-out of unwanted tracking and marketing. If not, marketers can expect legislation and/or regulation by the Federal Trade Commission (FTC) creating a federal mandate and a possible Do Not Track system like the FTC’s popular Do Not Call program.
New threats and regulatory proposals seem to be popping up everywhere, from proposals by the Federal Trade Commission and Department of Commerce, to hearings and proposed legislation in the Senate and the House. Meanwhile, the Coalition for Healthcare Communication, the 4A’s and other leading marketing companies are reminding policy makers of the industry’s opt-out program while urging more advertisers and agencies to participate.
“We believe that the industry has taken a strong leadership role in educating and protecting consumers in the online advertising arena,” said Dick O’Brien, head of the 4A’s Washington office. “The industry’s new self-regulatory program is up and running and providing consumers with effective and workable options to help them manage online advertisements.”
The members of the Digital Advertising Alliance include the 4A’s, the Association of National Advertisers, the American Advertising Federation, the Direct Marketing Association, and the Interactive Advertising Bureau. The Alliance program, developed in conjunction with the Better Business Bureau, has been operating since late 2010.
But the warnings keep on coming. For example, on March 8, at the 4A’s annual meeting in Austin, Texas, David C. Vladeck, director, FTC Bureau of Consumer Protection, told attendees that although the FTC “recognizes that behavioral advertising benefits consumers,” it also “raises serious privacy concerns.” Vladeck explained that the preliminary report issued by the Commission in December 2010, “Protecting Consumer Privacy in and Era of Rapid Change: A Proposed Framework for Businesses and Policymakers,” was intended to “spur industry to develop more robust and effective best practices and self-regulatory guidelines.”
FTC Calls for More Progress with Self-regulation
Vladeck said the FTC supports the industry guidelines and an opt-out mechanism. But while he finds them “encouraging,” he’s concerned that they are not yet widely adopted and apparent to users on the Internet.
“We’re concerned about [other] practices that subvert or undermine consumer choice, and our enforcement agenda reflects that concern,” Vladeck said. In his view, a successful Do Not Track mechanism should include five basic components, as follows:
- Be easy for consumers to use and understand;
- Be effective and enforceable;
- Be universal – consumers should be able to go to one place to exercise their preferences across the board;
- Allow consumers to opt out not only from the use of tracked data, but also from its collection; and
- Ensure that consumers’ choices will be persistent – they should not have to reset their preferences every time they clear their cookies or close their browser.
“We think the industry is up to the task of ensuring that both the design and implementation of the mechanisms it is developing will have those components and operate effectively,” Vladeck said, adding that any Do Not Track mechanism “should build upon existing industry innovations.”
Speaking on a 4A’s meeting panel to discuss the new program, Carla Michelotti, executive vice president and chief legal, government and corporate affairs officer for Publicis Groupe’s Leo Burnett, indicated that current self-regulation programs are not yet fully supported by many advertising agencies. “The self-regulation program is a very good program, but you need to read, understand and know where an agency fits in,” she said. Accordingly, the 4As and the Coalition will soon announce training programs for agency executives to increase awareness and participation.
Panelist Eric Mower, CEO of Eric Mower & Associates, emphasized the connection between privacy and stewardship, especially for agencies. “Any organization dealing with consumer data has a responsibility,” he said. “Voluntary self-regulation is just that – you do it because you feel responsible.”
Lack of Progress May Open Door to Legislation
Although successful self-regulation programs may need some tweaking, Vladeck does not believe that legislation is necessary to accomplish the FTC’s goals of protecting online consumers. However, his statement that the Commission has been “disappointed in the progress of self-regulation,” leaves the door open for legislative proposals. Two pieces of Do Not Track legislation already have been introduced in the House of Representatives; two more may be forthcoming.
The Do Not Track Me Online Act of 2011 (H.R. 654), was introduced Feb. 11 by U.S. Rep. Jackie Speier (D-Calif.) and would direct the FTC to develop standards for a Do Not Track mechanism that also would allow individuals to opt out of the collection, use or sale of their online activities. On Feb. 10, U.S. Rep. Bobby L. Rush (D-Ill.) introduced H.R. 611, the Best Practices Act, which would establish ground rules and privacy minimums for consumers, including “opt-in” consent to disclose information to a third party. Under Rush’s bill, companies that collect personal information would be required to disclose their practices and provide concise, meaningful and easy-to-understand notices of these practices.
U.S. Rep. Ed Markey (D-Mass.) also plans to introduce legislation that he indicates will include a Do Not Track provision so that children do not have either their online behavior tracked or their personal information collected or profiled. Additionally, U.S. Rep. Cliff Stearns (R-Fla.) is expected to introduce a privacy bill that will include a provision for an FTC-approved five-year self-regulatory program and would prescribe requirements for a self-regulatory consumer dispute resolution process.
On the other side of Capitol Hill, the Senate Commerce Committee will be holding a hearing March 16 to examine online consumer privacy – specifically commercial practices that involve “collecting, maintaining, using, and disseminating large amounts of consumer information, some of it potentially very sensitive and private in nature.” This hearing is the second in a series of hearings examining how users’ information is stored, collected and used. [Editor’s note: Senate hearings normally are streamed live on the Committee Web site. To access, go to: http://commerce.senate.gov/public/index.cfm?p=Hearings]
“Modern technology has connected people with the world and led to new innovations, new products and new experiences,” Commerce Committee Chairman John D. (Jay) Rockefeller IV (D-W.Va.) said. “But with these new opportunities come new risks. I want to know if the privacy protections we have in place are enough, or whether Congress needs to step in and do more.”
For further information, contact John Kamp at firstname.lastname@example.org. Add your comments on this important issue below.
Feb. 18, 2011 — Although marketers are pushing for the acceptance of voluntary programs that allow consumers to opt out of Internet tracking for marketing purposes, two bills were introduced in Congress last week that would provide the Federal Trade Commission (FTC) with the authority to both define and regulate online tracking.
On Feb. 10, U.S. Rep. Bobby L. Rush (D-Ill.) introduced H.R. 611, the Best Practices Act, which establishes ground rules and privacy minimums for consumers, including “opt-in” consent to disclose information to a third party. Under Rush’s bill, companies that collect personal information would be required to disclose their practices and provide concise, meaningful and easy-to-understand notices of these practices. The bill also includes safe harbors for companies who participate in a universal opt-out program operated by self-regulatory bodies and monitored by the FTC.
In Rush’s view, companies need the incentives provided by his bill “to agree to do these things,” he said in statement. “My bill would actually provide a sufficient mix of incentives for businesses not only to act in a more transparent manner with consumers but also to innovate and experiment with new business models … and to continue to offer relevant content and advertising to consumers who seek it.”
The Do Not Track Me Online Act of 2011 (H.R. 654), was introduced on Feb. 11 by U.S. Rep. Jackie Speier (D-Calif.). Speier’s bill would direct the FTC to develop standards for a “Do Not Track” mechanism that also would allow individuals to opt out of the collection, use or sale of their online activities.
Failure of a marketer to respect the consumer’s choice “would be considered an unfair or deceptive act punishable by law,” under this legislation, Speier said in a statement. “The federal government must have the authority and tools to enforce reasonable protections,” she said. Speier also introduced financial information privacy legislation (H.R. 653) on the same day.
In January, the Coalition for Healthcare Communication joined the Direct Marketing Association’s Internet Policy Comments to the U.S. Department of Commerce. These comments opposed the creation of a Do Not Track mechanism and consider mandatory Do Not Track provisions as preventing the flow of valuable consumer information.
Expanding the FTC’s authority in this area could be overkill, according to John Kamp, the Coalition’s director. “The current Do Not Track proposals offer a sledge hammer when a tack hammer is all that is needed,” he said.
He acknowledges that the balance between privacy and Internet convenience and utility needs to be met, but asserts that the industry has forged ahead to achieve this balance with an aggressive program that enables Web users to opt out of unwanted tracking and marketing. Indeed, “industry self-regulation is well ahead of the FTC and other government regulation efforts,” noted Kamp.
“As recent comments by the Coalition and others to the FTC and the Department of Commerce state, let’s give self-regulation and common-sense use by consumers a chance to develop before adopting dramatic, and possibly self-defeating, government regulation,” he said.
Feb. 15, 2011 — In a recent issue of Medical Marketing & Media News Brief, John Kamp, director of the Coalition for Healthcare Communication, weighed in regarding an op-ed piece on direct-to-consumer advertising in The New York Times written by Ian Spatz, a former vice president for global health policy at Merck, who currently works in the healthcare practice of Manatt, Phelps & Phillips in Washington, D.C.
Spatz contends in the piece that Congress should “pass legislation that would allow drug companies to cooperate with one another, and with physician and patient organizations, to develop joint ad campaigns that are specific to certain diseases and conditions but not to any particular drug.” Such ads, Spatz asserts, would allow pharmaceutical companies to “inform consumers about the disease; its treatment options, including pharmaceuticals; and how to gain further information not biased toward any particular brand.”
Kamp told MM&M that this concept is “simply a naïve idea, ignoring the realities of a competitive marketplace and the value of multiple products in a category – and let’s not forget the First Amendment.”
Feb. 14, 2011 — As more and more pharmaceutical companies explore the addition or expansion of social media marketing efforts, they are seeking to balance the perceived benefits of such marketing with the slow emergence of metrics to validate those benefits. However, it appears that social media marketing is gaining traction, according to a recent Harvard Business Review Analytics Service Report: “The New Conversation: Taking Social Media from Talk to Action.”
Roughly 79 percent of the 2,100 organizations surveyed by Harvard Business Review Analytics Services said they are either currently using social media channels (58 percent) or preparing to launch social media initiatives (21 percent). Among health/life sciences companies, in general, the Harvard report states that 48 percent of this industry sector is currently adopting social media for business purposes.
“Never before have companies had the opportunity to talk to millions of customers, send out messages, get fast feedback, and experiment with offers at relatively low costs,” the report states, noting the potential outreach opportunities provided by social networks. “It is that power that companies are seeking ways to harness, as social media has moved from the margins to the mainstream.”
“There is no question that pharmaceutical companies are interested in using social media and digital marketing to both grow their businesses and build relationships with doctors and patients,” according to John Kamp, director, Coalition for Healthcare Communication. “The question is how to use these tools in a smart, effective manner.”
Presently, only 7 percent of social media marketing users say they are able to integrate social media into their overall marketing strategies, the study states, likely due to the three primary challenges marketing departments face with social media: (1) understanding its potential to make a difference in their business; (2) measuring its effectiveness; and (3) aligning social media activities to an impact on company financials.
The pharmaceuticals industry seems on par with this integration statistic. An April 2010 article in the Philadelphia Business Journal reported that social media initiatives account for roughly 5 percent of drug companies’ total promotional spending.
The most effective social media marketing efforts, the Harvard report concludes, are those that do more than see social media as “a fad.”
Indeed, the report states that the most effective social media users are those that:
- Use more than one social media channel (four or more) and are more likely to do multi-media sharing and participate in review sites, discussion forums and blogs;
- Have developed and implemented a social media strategy and have a dedicated budget for social media activities;
- Are more likely to use social media to monitor trends, research new product ideas via social networks, have an online user group for customers and collect and track customer reviews on their Web sites;
- Are more likely to know where customers are talking about them on the Web and prioritize their social media activities accordingly; and
- Use metrics and analytic tools to measure results. The report stipulates that these metrics are evolving and there is “a good deal of uncertainty about which measures and tools should be used.”
Some in the industry are doubtful that social media marketing is a valid venue for the pharmaceuticals industry. Jonathan Richman, author of the Dose of Digital blog, contends that social media will never be an effective place to advertise pharmaceutical brands. Citing a study from Accenture, Richman states that only 6 percent of people get their healthcare information on sites like Facebook. He argues that individuals do not broadcast specific drugs that they are taking on social networks because there is no reason or incentive for them to do so.
Although Richman does not see a future in social media advertising for the pharmaceuticals industry, he does advise companies to use social media as another tool in their marketing arsenal. For example, he suggests that companies visit medical forums to answer questions about their drugs and develop social media strategies that do not involve Facebook, Twitter and YouTube.
At a November 2010 session at the DTC Digital Conference, moderated by the Coalition’s Kamp, Kathleen Onieal, a senior advisor with The Monitor Group and formerly global leader of marketing innovations at Merck, asserted that observing social media conversations can help to clear up inaccuracies that may pop up online. “It is almost a pharmaceutical company’s obligation to straighten out” misinformation in social media conversations, Onieal said.
As companies figure out which direction to take, regardless of their social media marketing strategies, they also need to bear in mind that the Food and Drug Administration’s Division of Drug Marketing, Advertising and Communications is preparing social media guidelines – now due by March – that may affect those plans.
Jan. 31, 2011 – The Coalition for Healthcare Communication (CHC) today signed on with other leading marketing organizations to the Direct Marketing Association’s joint industry comments regarding the U.S. Department of Commerce’s Internet Policy Task Force’s green paper, entitled Commercial Data Privacy and Innovation in the Internet Economy: A Dynamic Policy Framework.
The joint comments call for continued federal support of voluntary codes of conduct to protect consumer privacy while ensuring that the Internet remains a platform for innovation. The commenters also ask the Commerce Department to acknowledge that online advertising and marketing provide significant benefits to the economy, consumers and businesses.
“The CHC supports the joint comments because they recognize that the Internet is such an important and valuable tool for consumers seeking medication information,” said John Kamp, CHC executive director. “The comments’ call for self-regulation dovetail with our organization’s goal of assuring the free exchange of scientific information without undue government interference,” he noted.
A proposal introduced by the Commerce Department’s Internet Policy Task Force enabling Internet users “to express a uniform and persistent choice to opt out of online behavioral advertising – a concept known as ‘Do Not Track’” – is the type of government interference that could hamstring the flow of valuable consumer information, the comments state.
According to the comments, the federal government should not, either through legislation or regulation, engage in the creation of a Do Not Track mechanism, “because such efforts risk threatening the Internet as it exists today, an area of American innovation and dominance, and a primary area of job growth and investment.”
The commenters contend that an About Ads Consumer Opt-out Page – a voluntary, self-regulatory program initiated in late 2010 – gives consumers data about the companies that have enabled customized ads on their browsers and allows them to opt out of some or all of the companies participating if they so choose.
“Although the CHC recognizes the right of citizens to protect their sensitive medical data, a government-imposed ‘Do Not Track’ list could cripple the ability of citizens to use the Internet for vital health information,” Kamp said. “Balancing legitimate privacy requests with the need for a robust Internet that offers healthcare professionals, patients and caregivers immediate access to useful data about medical conditions and treatments is not easy, but it is what all parties need to establish as the primary goal,” he remarked.
The CHC asserts that limiting or preventing access to free commercial speech is not the solution, according to Kamp. “Without free access to appropriate medical information, the lay public will not be able to assume greater responsibility for its own health, a critical factor in the nation’s effort to achieve efficient and effective usage of the healthcare system,” he said.
Although 2011 brings political party shifts in Congress and new challenges, the mission of the Coalition for Healthcare Communication (CHC) remains the same: To protect, for society and individual patients, the benefit of the free flow of healthcare information. This year the CHC will be focusing on four major issues: (1) tax treatment of marketing costs; (2) “transparency,” conflict of interest and collaboration; (3) proposals to limit the collection and use of Rx and consumer medical data; and (4) FDA DDMAC’s policies and guidelines (including social media guidelines). The 2011 Focus of the Coalition describes the issues CHC will be tracking in 2011, the political climate in which those issues will be debated and how potential outcomes could change the Rx communication business and affect the public health.
2011 Medical Marketing Predictions published in
Medical Marketing & Media, December 30, 2010 — by Matthew Arnold
Will 2011 be the year FDA loosens up and opens the floodgates on a flurry of big new approvals? More seriously, will they get around to issuing social media guidance for pharma before Baby New Year morphs into Father Time again? We have no idea, but we did ask some of the smartest folks we know in medical marketing about their predictions for the industry in 2011.
Here’s what they told us: http://bit.ly/fV5Prv
Start the New Year right. Add your predictions to those of John Kamp, Nick Colucci, and other industry leaders.
John Kamp, executive director, Coalition for Healthcare Communication
- Congress will raise the medical marketing tax issue as it searches everywhere to find revenue. Indeed, a high profile member of Congress will propose the elimination of the deductibility of all marketing costs for all industries. The deficit will simply be too big to ignore, and virtually every good and bad tax idea will be discussed.
- The Federal Trade Commission chairman and Senate Commerce Committee chairman will support strong new digital tracking limits, especially on “sensitive issues” including medical information. New Republican leaders of the House Commerce Committee will be less enthused.
- The FDA will publish the first of several documents addressing internet and social media. Although useful, medicine and device companies will continue to be very careful, especially with social media. Independent internet publishers will continue to innovate and create sites that are industry friendly and companies will expand their visibility by advertising on those sites. Progress will remain slower than for consumer goods, but growth on our industry also is inevitable.
- Industry and government payers as well as provider groups will continue to look to medicine and device manufacturers to help them manage their financial risks in insuring and treating patients. Medical manufacturers and their agencies increasingly will be developing programs for payers and providers that foster compliance with best practices and standards of care. Everyone involved will be looking to improve efficiencies by improving patient care. Every industry sector and patients will benefit.
- The FDA and HHS will continue to push for “parallel reviews” of device and drug approvals by FDA and reimbursement decisions by HHS. Everyone involved will be tentative and skittish.
- PDUFA 2012, FDA REMS and HHS Comparative Effectiveness will be on the top of everyone’s list of worries and opportunities.
- Electronic medical records will inch toward reality, creating optimism and consternation everywhere.
Arnie Friede, principal, Arnold I. Friede & Associates
We can expect more, and even more aggressive, enforcement from FDA in general and DDMAC in particular in 2011. I think that the impending social media guidance will be largely unhelpful and will raise more questions than it answers, if it even emerges at all. This is a year when pharma and the agencies that work with the industry ought to be reminded about the need for proactive engagement in FDA legal and regulatory matters. It makes no sense to wait until the defecation hits the ventilation, i.e. to wait until you get a Warning Letter or NOV from DDMAC. It may be too late to fix the problem given all the liabilities that go along with being a recipient of such correspondence. On the contrary, I encourage everyone to anticipate and address problems up front. That is the only way to manage risk reasonably in the current hostile enforcement environment.
Debrianna Obara, VP, media, Razorfish Health
In the digital world of health, more and more brands will focus on distribution of content as opposed to straight display media or search buys. This shift will allow brands who have invested in educational and branded content to amortize that investment by getting more health seekers to interact with that content. The user benefits, as they can interact with valuable information without leaving their trusted 3rd party website of choice (such as AOL/Yahoo!/WebMD).
Dana Maiman, CEO, Draftfcb and CEO/president, Draftfcb Healthcare
More and more clients will be looking for wholly integrated, multi-channel solutions within one agency offering, realizing that bundled services are far more efficient and effective for their brands.
Nick Colucci, president and CEO, Publicis Health Care Group
REMS revolution: REMS will shape the way companies spend their marketing dollars. REMS not only maximize brand value, but help meet the drug development needs of the future.
Acquisitions abound: 18 of the biggest drugs in the world will lose patent protection in the next five years. As revenue from blockbuster brands and mature markets decline, companies can use their balance sheets to “buy” promising portfolios and local companies in emerging markets.
Personalized medicine momentum: personalized medicine has always represented a bet on the future; however, forces now converging suggest its benefits are within reach for patients, payers and providers. We are beginning to see the possibilities, using data to improve personal care. Product marketers need to be prepared to narrow their focus and develop more capabilities in analytics and market access.
Regulatory rigor: new officials promise stiffer marketing enforcement. Warning letters are an immediate reaction and can be sent with a push of a button. Marketers need to be hyper-vigilant and turn around responses and justifications with haste and content to avoid triggering more aggressive Beltway engagement.
Sample reporting: beginning April 2012, pharma companies will be required to report sample-distribution activity. While tracking is not new, we will see turn-key solutions to manage sample compliance proactively. Programs that provide (and verify) access to clinical starters without personal rep visits will be used more frequently to support broad geographical needs.
Alternative reps: physician face-time availability and sales-force resources are diminishing. Still, a need for information demands innovative techniques. Most major pharma companies are now working with outsource providers to achieve their outreach needs. Meanwhile, others are turning to digital sales tools, including e-details, online seminars and virtual-training sessions.
Focus on payers: insurance companies in particular will want to see comprehensive value propositions backing up all claims of clinical efficacy and cost effectiveness with rigorous data and peer-reviewed articles. This means we will have to start considering payer needs as early as Phase II.
Michael Golub, MD, chief medical officer, Digitas Health
It won’t take long for large healthcare systems to gain the ability to mine data from their electronic health records to determine the outcomes related to–and cost-effectiveness of — pharmaceutical products. Look for one or more major pharmaceutical companies to begin exploratory talks with the FDA regarding the criteria that would allow data licensed from large healthcare organizations to be utilized within the marketing arena.
As use of the iPad within healthcare continues to expand, look for disease state education to quickly migrate to iPad-friendly (and similar-device compatible) platforms. These devices offer the benefits of mobile versatility and instant digital channel connectivity (in space and time) with a screen size suitable for integration into the doctor-patient dialogue.
Alfred O’Neill, group VP, client engagement & strategy, Razorfish Health
We’ll see more pharmas following the consumer and letting one person personify the brand in social media, with a better understanding of how to use social media to personify the brand and drive cost-effective patient eCRM. Using the mentor of the Facebook page as “host” and voice of the eCRM adds credibility and humanity where currently most biopharma eCRM is one-size-fits-all.
We may move to a model where a patient advocate is assigned a Facebook or community site attached to it that allows for a different form of engagement with content. The content is RC approved, but the “patient owner” is the face of the Facebook community, and could be the one to encourage signing up for eCRM and other apps to keep the sharing going. Sharing in this sense can be controlled and open fields, adverse events and other hurdles are addressed.
Lilly is committed to providing “Answers That Matter.” That means not only discovering and developing innovative medicines – which we believe offer the best value in healthcare – but also engaging in ongoing dialogue with patients, providers, payers, and the public. Our vision at Lilly is to deliver improved outcomes for individual patients.
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