Sunday, January 31, 2010

A Pharma "Social Media Working Group" Submits Comments to FDA

Pharma's Social Media Working GroupA group called the "Social Media Working Group" (SMWG) comprised of representatives from Amgen, AstraZeneca, Bristol-Myers Squibb, Millennium Pharmaceuticals, and sanofi-aventis U.S., recently submitted written comments to Docket No. FDA-2009-N-0441 (see here) regarding Promotion of Food and Drug Administration-Regulated Medical Products Using the Internet and Social Media Tools. You can find the SMWG's comments here.

Two significant things to keep in mind about the SMWG and its comments are: (1) the companies that are missing from the group (such as Pfizer, UCB, GSK, Merck, Novo Nordisk, etc.), many of which have engaged in social media, and (2) the non-binding nature of the suggestions made by the group; ie, "each representative of the SMWG continues to remain free to have independent opinions on issues presented..."

You may recall that the FDA requested feedback from the drug industry and other interested parties on a number of specific questions, most of which relate to social media. At a November, 2009, public hearing, the FDA heard mostly from drug companies and their agencies (see "Industry Groups will Eat Consumer Advocates' Lunch at FDA Social Media Public Hearing")

In its comments to the FDA, the SMWG focuses on how to handle off-label comments (ie, comments about product information or use that is not consistent with the FDA approved full prescribing information), how to submit to promotional posts to FDA, and how to deal with adverse event reports on social media sites that are either owned by them or by independent 3rd parties.

Guidelines Needed
"If companies choose to monitor the site," says the SMWG, "they should consider establishing guidelines for anticipating, monitoring, and responding to unsolicited off-label comments and questions posted by third-party visitors within company-hosted online communities." These guidelines would be communicated to online community members via a Terms of Use agreement. "FDA could require that companies monitor such sites/communities on a regular basis (each business day, for example) to ensure compliance with the Terms of Use and take appropriate action when the Terms of Use are violated."

For product-related sites, the SMWG recommends the following Term of Use:
This site is intended as a forum for discussing FDA-approved uses of [product x], which are [insert approved indications]. As such, postings containing product discussions that are not consistent with the FDA-approved prescribing information (include hypertext link to full prescribing information) are subject to removal. Product-related questions should be directed to Customer Service or [other appropriate department for handling] at [toll-free number, fax, email].
Censorship vs. Moderation
With regard to responding to unsolicited request for off-label information, the SMWG recommends that the site "retain the off-label request posting, along with the company acknowledgment, to ensure the community is informed of its off-label nature. This avoids the risk of an off-label question being viewed without clarification" and also avoids, as the SMWG says, "undue censorship."

I have a problem with this. First of all, the cat's out of the bag if you allow unsolicited off-label posts to be retained, even if for a short period of time. Given the viral nature of social media such as Twitter, the post can be replicated throughout the Internet within hours and reach the top of search engine results.

The SMWG is a bit vague on how long off-label posts should be retained and leaves it up to individual companies to decide: "The company would remove the off-label posting/statement within a reasonable time to ensure availability of this information is limited. Companies should also determine criteria for type of information to be addressed/corrected and length of time information would remain online."

A better way to handle this on sites owned by pharmaceutical companies is through enlightened moderation. This is how I handle comments made to this blog. You may call it "censorship," but reviewing comments before they are posted has become the norm for pharma companies that now have blogs (ie, Johnson and Johnson and GSK, neither of which are part of the SMWG).

IMHO, any Terms of Use policy of a company-owned social media site should include moderation of posts BEFORE they are published and denying publication of any post that mentions off-label usage. The Terms should also specify what is meant by "off-label" usage as I am sure not many consumers realize that their physicians may be prescribing a product for a use that has not been approved by the FDA.

Form FDA 2253 Submission
The SMWG recognizes that FDA's requirement that drug companies submit all promotional materials at the time of initial dissemination is "particularly challenging for social media, which involve real-time dialogue among community members." The group suggests that, for company-owned sites, the following items be submitted on Form 2253:
  • Static elements (graphics, indication, important safety infonnation, package insert link, etc.)
  • Proactive promotional company postings such as those intended to introduce a topic for discussion
  • The site's URL, which would constitute a submission of the online discussion by reference
"An alternative to the time of first use submission is to batch and submit discussion threads occurring within company-hosted discussions. These could be captured and submitted on a weekly or monthly basis."

This alternative idea seems to include ALL posts made on the site, not just the "proactive promotional company postings." If the site is a successful social media site, the number of postings can be large. It could become a burden for the FDA to review all this material! Of course, the industry may pay for this through new user fees, but that would require an act of Congress. Not likely in this do-nothing political era!

Note: For further discussion of this issue, including results from a recent Pharma Marketing News survey, see "How Should Pharma Companies Submit Social Media Content for FDA Approval?"

Image credit:

Friday, January 29, 2010

The New KOL: Your Local Community Doctor

Matthew Herper, contributor to Forbe's The Science of Business blog, suggests that an "unintended consequence" of regulating financial conflicts of interest in medicine -- eg, academics taking big speaking fees from drug companies -- is that the drug industry "can make experts out of community docs, then use those for speaking. Cutting them [drug companies] off from paying the academics just keeps the academics out of the system. It doesn't get rid of the system" (see "The Pharma Marketing Hydra").

I found this insight interesting because I just finished writing a Pharma Marketing News article related to this issue: "Corporate Reputation in the New Media World: Influencing the New Influencers" (PMN reprint #91-02). In that article, Gary Bartolacci, Senior Director, Kantar Health, cited research that questioned the traditional idea of thought leaders being perceived and defined by prestigious titles, number of publications, and speaking engagements. Other physicians may not fit that definition but are nevertheless quite influential, said Bartolacci, especially at the local and regional levels.

Influential physicians who are hired by pharmaceutical companies to speak about new therapies to other physicians are called "key opinion leaders" (KOLs). The problem with traditional KOLs is that many of them are usually so busy that they may not have the time to participate speaking programs.

But more and more KOLs are facing a more difficult choice: either stop moonlighting as a paid speaker for pharmaceutical companies or quit their jobs at top medical schools and teaching hospitals that restrict or ban participation in speakers’ bureaus.

Recently, the Boston Globe reported that Lawrence DuBuske, "an allergy and asthma specialist and a Harvard Medical School instructor [and Executive Editorial Board Member of the journal Allergy & Asthma Proceedings], will resign from Brigham and Women’s Hospital at the end of the month" (see article). As I reported in the article "Pharma Begins to Reveal Payments to Physicians" (PMN Reprint #91-03; also see this Pharma Marketing Blog post: "Why Does GSK Prefer New York Physicians & Will Governor Patterson Ruin It for Them?"), DuBuske received the highest total payment made by GSK for speakers in Q2 2009: $99,375.

Not many physicians on GSK's KOL payment list received nearly as much money as did DuBuske. Here's what GSK's distribution of payments looks like:

Key opinion leaders may also be found online using social media tools like Facebook and Sermo. “There may be newer doctors who are incredibly influential on social media sites who are not considered key opinion leaders in the real world or who are completely unknown to companies,” noted Bartolacci.

I find it interesting that the "unintended consequence" of physician payment sunshine laws may actually be helpful to the drug industry by encouraging it to break away from the academic KOL strategy to what may be a more effective strategy of using community doctors. And by "community," I also include online communities like Sermo (see "Pfizer has a Gold Mine in Sermo!").

See "Corporate Reputation in the New Media World: Influencing the New Influencers"

Wednesday, January 27, 2010

Why Does GSK Prefer New York Physicians & Will Governor Patterson Ruin It for Them?

In the January issue of Pharma Marketing News, which will be published today, one article focuses on payments made to physicians by Merck, GSK, and Lilly (see "Pharma Begins to Reveal Payments to Physicians: Analyzing the Numbers to Spread the Sunshine"). Figures 2 and 3 from that article are reproduced below:

New York stands out as a state receiving not only the highest total payments (#1 for GSK and #2 for Merck), but also on a per physician basis. If all the money GSK paid to physicians in NY were spread equally among all the 26, 716 physicians in the state, each physician would get $70.17. In comparison, for Merck that number would be $12.06 per physician, which is low by comparison with GSK, but still the highest for any state in Merck’s dataset. California’s physicians, on the other hand, did not seem to get enough compensation to adequately educate its large physician population. In other words, if pharma payments to physicians are primarily to help educate physicians about products, then California physicians are getting less education than NY physicians.

"Does anyone have any ideas as to why GSK might fund a disproportionately higher number of New York based health care providers compared to other states?," asks Eric Milgram, who writes the Pharma Conduct blog. See his analysis of GSK's payments to physicians here: "An Analysis of GSKs Speaker and Consulting Fees for 2009 Q2." Great minds think alike!

Neither Eric nor I have an answer to the question posed above. But now I know why my niece's husband wants to practice medicine in New York! Just kidding, Nick! I know you are one of those medical students who refuse to receive gifts from pharma companies. BTW, Nick, did you know that New York's Governor Patterson is proposing to prohibit "Inappropriate Gifts to Doctors" by pharmaceutical companies in an effort to balance his state's 2010-2011 budget?

According to the Governor's Briefing Book:

"Pharmaceutical companies and their representatives would be restricted from providing inappropriate gifts or misleading/inaccurate information to doctors to promote utilization of a drug."

"This will benefit patient care and reduce costs in the Medicaid program, as more expensive drugs will not be prescribed for the wrong reasons," Paterson said (see "New York Governor Proposes Limits on Access to Pharmaceutical Information").

The estimated savings? 2010-11: $0.3 million; 2011-12: $0.5 million

New York faces a $7 billion 2010-11 budget deficit. A $0.0003 billion savings here and a $0.0003 billion savings there and pretty soon -- about 23,333 years and 4 months to be exact -- you will have a balanced budget!

But will GSK continue to reward NY physicians with lucrative speaking and consulting gigs if this budget is passed that includes the restriction on gifts to physicians?

This still does not answer the question about why GSK favors NY physicians... But wait, I think that I have the answer to the question! GSK has anticipated Patterson's proposal to stifle pharma largesse in New York and has disproportionately given physicians in that state lucrative speaking and consulting jobs to endear them to its cause and fight against the restrictions proposed by Patterson!

No that can't be right! California probably has a larger budget deficit than does New York. Yet it's not getting a disproportionate amount of physician fees.

If you have the answer, please let me and Eric know. We are planning to do a podcast together on this subject.

Tuesday, January 26, 2010

J&J, BTW, IS Donating to Haiti Relief But Won't Say How Much

I've been keeping a tally of the donations that the drug industry is making to the Haiti earthquake relief effort. So far, the total of about $9 MM in cash and $15 MM worth of drugs and other medical supplies is only about 14% of what the industry donated to tsunami relief in 2005 and only about 1.2% of the daily sales of Rx drugs worldwide (see "So Far, I Have Donated More to Haiti Relief Than Pharma (as % of Daily Income)").

After several days of my incessant Twitter badgering, Marc Monseau, Director, Corporate Communication, Social Media, at Johnson & Johnson, finally "answered" my question about how much J&J is donating to Haiti. See below for Marc's accounting of J&J's Haiti relief efforts.

Unfortunately, no dollar amount of J&J's contribution is available. "We typically don’t disclose the dollar value of our contributions to individual relief efforts," said Marc. In 2005, however, PhRMA reported that J&J donated $10 MM in cash to tsunami relief. I guess the 2004 tsunami in Indonesia was NOT "typical" whereas the Haitian earthquake is.

If you say that the amount is not important, I say it is, especially when you make a BIG splash about helping Haiti on your web site's home page as J&J is doing (see screen shot below; see

J&J is doing good. But how much good compared to Abbott, for example, which is donating $1 MM in cash to Haiti (BTW, that's only 10% of the $10 MM Abbott donated to tsunami relief in 2005)?

A dollar value is the only way to measure how much good J&J is doing, not a video on its web site. Cash donations, we are told, are the BEST way to help Haiti right now. Individual Americans are donating more cash to Haiti than the drug industry. The Help for Haiti Now TV marathon, for example, raised about $35 MM from viewers in a single night. I am sure that many employees of pharmaceutical companies are also making donations. It's great that J&J and many other companies are matching these donations (J&J is offering a generous 2:1 match -- Marc mentioned that 1,700 J&J employees have already made donations. See bullet points below). I hope that they tell us the dollar value of those matching funds because that would tell us something about the generosity of their employees, which I am sure matches or even surpasses that of Americans in general.

The following is Marc's accounting of J&J's Haiti relief efforts
  • We immediately shipped Johnson & Johnson disaster relief modules with large quantities of our consumer and over-the-counter products.
  • We also are coordinating cash donations to organizations known to us and our regional colleagues to assist with initial aid. Our partners at Medical Teams International (MTI), the Surgical Implant Generation Network (SIGN), and Esperanza International are on their way to Haiti to evaluate the situation on the ground as well as to offer emergency medical treatment.
  • Our Family of Companies in Latin America and the Caribbean are in contact with Haitian and Dominican nongovernmental organizations such as Hospital Albert Schweitzer, Esperanza International and Partners In Health to assess on-the-ground needs.
  • Our companies will be preparing additional product donations based on needs identified by these and other partners.
  • Additionally, we are evaluating maritime capacity for shipping products from Puerto Rico to Haiti, and activating contacts with our distributors in Haiti and the Dominican Republic to understand logistics of moving donated products from the ports and airports into the affected areas.
  • We are offering 2:1 company matches on donations made by U.S.-based employees to qualified nonprofit organizations assisting with earthquake relief efforts in Haiti.
  • We are continuing to monitor the situation and, based on what we learn from our partners, will evaluate how we can help in other ways in both the short and longer term.
  • Our partners helped to airlift disaster relief modules into Haiti last week that included large quantities of our consumer, pharmaceutical, and medical device and diagnostic products – enough to meet the immediate needs of thousands of people. Antibiotics and pain medications have been donated for use in acute care.
  • Specialized medical devices to assist with traumatic limb and body injuries are being provided to qualified surgical teams. Large shipments of our first aid and consumer hygiene kits were donated.
  • This expanded list of partners reflects the progress we have made in the last week working to identify needs and ways to help: AmeriCares, Catholic Medical Mission Board, Direct Relief International, Esperanza International, Heart to Heart, Hôpital Albert Schweitzer (Pittsburgh), Interchurch Medical Assistance, International Rescue Committee, MAP International, Medical Teams International, Operation Smile, Partners In Health, Project HOPE, Save the Children, SOS Children’s Villages, Surgical Implant Generation Network, UNICEF, and United Nations Population Fund (UNFPA).
  • In the U.S., more than 1,700 employees have donated to one or more of our partners through our U.S. Matching Gifts Program where employee donations are matched 2:1 by the company. Some of our operating companies outside the U.S. have their own programs.
I hope this helps. Call me if you have questions.

Marc Monseau
Director, Corporate Communication, Social Media
Johnson & Johnson
One Johnson & Johnson Plaza
New Brunswick, New Jersey 08933

W: (732) 524-1130

Monday, January 25, 2010

Seroquel XR Print Ad Imitates Art, But That's Not the Real Problem

There's a bit of brouhaha in the Twitterverse about a recent Seroquel XR print ad that imitates the art of Chinese artist Liu Bolin (see "Liu Bolin and JaeSelle - what's the connection?"). "Both feature people camouflaged against their backgrounds so that they almost disappear," said Jim Edwards over at bnet. Some say this is a despicable corporate ripoff of art. Here's the ad:

Personally, I don't find anything wrong with advertising images that are inspired by artists and I certainly do not think Liu Bolin has any case against the ad agency (Saatchi & Saatchi Healthcare) for copyright infringement.

When I first saw this ad, I didn't get the connection because (1) I didn't notice the camouflage effect, and (2) I had never heard of  Liu Bolin, nor seen his art. So I am happy the ad introduced me to the world of Liu Bolin and I can now better understand the ad's message, thanks to Jim Edwards et al. Too bad that message escaped me when I first saw the ad, as I am sure it escaped many other people.

The real problem with this and so many other Rx drug print ads is the extraordinary amount of space devoted to imagery. In this case, 50% of the 2-page ad consists of the image. Of course, there's a statement about bipolar depression within the graphic. This is meant to explain what the graphic depicts -- something Liu Blin would not do with his art -- and only indirectly the benefit of Seroquel.

What I think is the real problem of this Seroquel XR ad  is the lack of benefit information and the space wasted on the image. While the ad devotes quite a bit of space -- maybe 40% -- to risk information (not including the 6 pages of legalese that follows the ad), only about 10% of the ad (not including the statement within the image) is dedicated to benefit information.

How does this compare with other print ads? The following Cybalta ad, which appeared in the WebMD Little Blue Book Rheumatology edition, was cited by the FDA for "[failing] to present risks associated with a drug with a prominence and readability reasonably comparable with the presentation of information relating to the effectiveness of the drug" (see here):

About 37% of this ad -- if you consider this 2-page spread a single ad -- is devoted to benefits. Although 50% of the ad is devoted to risk information, the FDA was not satisfied: "This efficacy claim is presented in very large bolded yellow font on a blue background with significant white space. The risk information is presented on the preceding pages in black, smaller font size, in single-spaced paragraph format, and the header “Important Safety Information for Cymbalta® (duloxetine HCl)” is presented two pages before the efficacy claim (in the reverse order in which this information is typically presented), making it not visible to viewers looking at the efficacy spread. This overall presentation misleadingly minimizes the serious risks associated with Cymbalta because it fails to convey this important risk information with a prominence and readability reasonably comparable to the efficacy claim."

The Seroquel ad, therefore, is not likely to catch any grief from the FDA as did the Cybalta ad. But there are plenty of ads out there that do not include enough fair balance.

Some time ago, I collected over 60 print drug ads that appeared in several major consumer magazines and measured the space allocated to images, benefit statements, risk information, and the brief summary. What I found was that, on average, the images in these ads occupied 46% of the total ad space (similar to the Seroquel ad), whereas benefit statements took up 19% and risk information about 12%. The chart below summarizes my findings:

You can read about my Print Ad study here: "Print DTC: How Does It Measure Up?" (pdf; FREE!)

Thursday, January 21, 2010

Drug Industry Innovation: GSK's LOVAZA Vs. OTC Omega-3 Fatty Acid Supplements

The pharmaceutical industry is often criticized for developing new Rx drugs having little value over current medications. Such drugs are called "me-too" drugs because of their similarity to existing Rx drugs. Glaxo has now taken this to a completely NEW level: developing an Rx drug that is a "me-too" of existing over-the-counter dietary supplements. I am talking about LOVAZA, aka omega-3-acid esters approved by the FDA for the treatment of high triglycerides. Here's the ad for LOVAZA, which I cut out of this week's Newsweek Magazine (click on it for an enlarged view):

LOVAZA seems identical to the Member's Mark brand of Omega 3 Fish Oil that I can buy at my SAM's Club store for about $18 a bottle. This bottle includes 400 Softgels and will last me 3-4 months if I take the recommended 4 1000mg softgels per day -- that works out to be about $5-6 per month.

Is LOVAZA different than the OTC (over-the-counter) product I have in my kitchen cabinet? Here's how they compare (check out the LOVAZA package insert here):

Dosage Form: MM, 1000 mg softgel; LOVAZA, 1000 mg softgel

Dosage: MM, 4 softgels per day; LOVAZA, 4 softgels per da

Active Ingredients: MM, 300 mg of 3 Fatty Acids (EPA and DHA); LOVAZA:  Each 1-gram capsule of LOVAZA contains at least 900 mg of the ethyl esters of omega-3 fatty acids sourced from fish oils. These are predominantly a combination of ethyl esters of eicosapentaenoic acid (EPA - approximately 465 mg) and docosahexaenoic acid (DHA - approximately 375 mg).

Hmmm... the major difference is that LOVAZA contains more EPA and DHA than does the Member's Mark OTC version (465 mg of EPA and 375 mg of DHA vs 300 mg of EPA+DHA, respectively).  That's about 2.8X more, which means I would have to take 11 MM softgels per day to equal 4 LOVAZA sofgels (the LOVAZA Web site says "It could take up to 14 capsules per day of an omega-3 supplement to provide the same amount of active ingredients proven to lower very high triglycerides"). My 400 MM softgels would then last me only 1 month or so. That raises my monthly cost to about $18. Bummer!

But wait! What if I were prescribed LOVAZA? How much would it cost me? I'm willing to bet that my insurance company might balk and make the co-pay very high -- say $25 -- or insist on substituting an OTC equivalent, even it means I have to take more pills per day.

So, LOVAZA is likely to cost me about 38% more than Member's Mark Omega-3, but be more convenient because I only have to take 4 of them per day. Note: GSK offers a savings card that allows me to save up to $20† off each of my next 12 refills of LOVAZA. I've tried to find the footnote referenced by that (†) symbol, but can't seem to find it on the Web site. My old eyes may not be good enough. Besides, I probably don't qualify for the full $20 discount -- I never win anything!

My prediction is that LOVAZA is not going to be popular with people like me -- older men with high triglycerides. First, I hate refilling prescriptions and if you think I am going to carry around ANOTHER card in my wallet, you're crazy! Secondly, I am already pissed off that as soon as Abbott came out with its industrial-strength Rx version of NIACIN in combination with something else (I forget exactly what), I can no longer find the right kind of OTC niacin in CVS as I used to. I suspect that CVS took it off the shelf in order to sell Abbott's Rx version (previously, the CVS pharmacist recommended the OTC version, now he is silent about it).

I would love to have been part of the focus group that GSK studied before it began marketing LOVAZA. You did have a focus group, didn't you?


Why Did the FDA Approve LOVAZA In the First Place?

Nevermind that this is a "me-too" product that has no business being an Rx drug because there are so many OTC equivalents out there. It is also of dubious value because the data supporting its effectiveness (vs. placebo) is questionable. Here's a table from the prescribing information relating to adverse events:

Note the N values: 226 and 228! If these are the number of patients in the clinical trial, as I suspect they are, then the trial did not include enough patients to prove anything, let alone effectiveness! I am certain you cannot get from 228 data points any significant results that rise above the level of pure chance!

Wednesday, January 20, 2010

Pfizer Donates Animal Health Products to Haiti

"Pharma Digs Deep for Haiti Relief" proclaims this headline. Not deep enough according to my accounting!

As you may know, I am keeping score regarding the pharmaceutical industry's donation of money and drugs to Haiti earthquake relief. Although many companies have pledged donations, most of those donations are rather small, especially when compared to the donations the industry made after the Christmas 2004 tsunami in Indonesia (see "So Far, I Have Donated More to Haiti Relief Than Pharma", for an up-to-date accounting). Some rather large companies such as J&J, Roche, and BI have not yet specified what, if any, donations they are making.

Pfizer is playing it close to the vest as far as revealing exactly what its commitment is. Pfizer's Jennifer Kokell, Communications Strategy, Issues Alignment, and the person behind Pfizer's Twitter account (@pfizer_news), answered my inquiry about her company's Haiti relief efforts in this email:
---------- Original Message ----------
From: "Kokell, Jennifer"
Date: January 19, 2010 at 9:50 PM
Subject: Pfizer - Haiti

Hi John,

In response to the devastating earthquake which recently impacted Haiti, Pfizer has been working with several non-government organizations to make a substantial pharmaceutical and animal health product donation and determine the most effective and efficient distribution and allocation of the products for the people of Haiti.  The company will make a monetary donation to designated NGOs and will also match all donations made by its U.S. employees through its "Pfizer Foundations Matching Gifts Program".

(Product donations will include Zithromax and Diflucan, among others)

Our thoughts and hopes go out to all of the people of Haiti and their families throughout the world.


I think this is very non-committal and not a good "communications strategy." For all I know, Pfizer's main donation to Hiati may be the "animal health products" Jen mentions in her email (seems like the animal health division of Pfizer wants to be sure it is part of the company's communications strategy). No dollar amounts are mentioned, although I've heard "hundreds of thousands" of dollars from other sources. Maybe Pfizer is carefully assessing the situation before it makes a public commitment. Who knows? It's all so vague.

Compare this vagueness to Pfizer's donation to 2004 tsunami victims of $10 million in hard cash and $25 million worth of healthcare products.  If we assume that "hundreds of thousands" means $300,000, then Pfizer is giving only a TINY fraction of that (eg, 0.9%) to Haiti (and some of it for Haitian animals)!

Merck and BMS have have pledged to Haiti relief only 20% of what they gave to tsuanami relief.

J&J has not yet responded to my inquires.

Monday, January 18, 2010

So Far, I Have Donated More to Haiti Relief Than Pharma (as % of Daily Income)

So far, global pharmaceutical companies have donated or pledged to donate about $9 million in cash and an additional $15 million or more worth of drugs or medical supplies to Haiti earthquake relief. Some have pledged to match employee donations as well (see table below for up-to-date numbers). The cash donation represents about 0.4% of the daily global sales of prescription drugs (IMS estimates global drug sales totaled $750 billion in 2008 or about $2 billion per day).

In contrast, Cheap Joe's Art Supplies -- where I sometimes shop -- pledged to donate 5% of the sales it made last Friday. Cheap Joe sent me the following notice by email last week:

If Cheap Joe can donate that amount relevant to sales, why can't the pharma industry do it too? Even I can afford to donate that much. I just donated about 4% of my daily income to the Clinton/Bush Haiti Fund. A few dollars more and I will reach 5%!

Here's my pharma Haiti relief tally so far (Feb 12, 2010):

pharma Haiti relief tally chart

If your company is not on this list, please let me know. If you have more correct, up-to-date data, also let me know. My email address is

P.S. Some companies (eg, Novartis) report a total contribution that includes the cost of drugs and medical supplies donated. Of course, those costs can be inflated manufacturers' suggested retail prices (MSRP) rather than wholesale prices or typical market prices.

P.P.S. Generic drug manufacturer Teva just announced on CNBC that it would donate $7 million worth of drugs to Haiti relief. $7 million is 5-30 times what brand drug companies are donating. I wonder how they calculated that number? Maybe they used the MSRP of the branded versions of their drugs? But it's all good.

P.P.P.S. Compared to pharmaco donations for the 2005 tsunami relief effort, the Haiti numbers seem small (it is estimated that total pharma tsunami relief was $170-180 MM). Here are some numbers from 2005 (see "Drug Companies Give Aid to Tsunami Victims"):
  • Pfizer will donate $10 million to local and international relief organizations operating in the region. Pfizer will contribute approximately $25 million worth of the company's healthcare products which includes the anti-infective products Zithromax, Zyvox and Diflucan.
  • Merck & Co. Inc. is giving $3 million in cash while Johnson & Johnson and Abbott Laboratories Inc. are each donating $2 million; each of the three are also sending drugs and other health care supplies to the region. Bristol-Myers Squibb Co. is donating $1 million in cash and $4 million in antibiotics and antifungal drugs. Roche Group and GlaxoSmithKline PLC were also planning to donate supplies and/or cash.

Social Media Vs. Social Responsibility: J&J Fails Crisis Management 101

The New York Times reports that "Johnson & Johnson appeared to abandon its own template [ie, the gold standard in brand crisis management], stunning a few business school professors. Its conduct also drew harsh criticism from federal officials" (see "In Recall, a Role Model Stumbles").

At issue was the slow response to reports of contamination of popular over-the-counter medicines, including Benadryl, Motrin, Rolaids, Simply Sleep, St. Joseph Aspirin and Tylenol.

In a letter to Peter Luther, President, NA OTC, McNeil Consumer Healthcare (see end of this post), FDA said "We are aware of the complaint information available to your company, the sequence of events, and the extent of your firm's follow up measures during this period. We have concluded that your company did not conduct a timely, comprehensive investigation."

The New York Times took J&J to task for not covering this in its coporate blog: "Johnson & Johnson’s conduct is all the more out of step, analysts said, because the drug maker had been one of the first in the pharmaceutical industry to set up its own blog, of Sunday at 6 p.m., on the issue of the current recall, the blog so far has had no comment from the company."

Marc Monseau is responsible for the JNJBTW Blog and he also writes posts to the @JNJComm Twitter account. Marc made two posts to this account on January 15, one at 4:40 PM: "McNeil Consumer voluntarily recalls certain over-the-counter products @McNeilrecall" and one at 4:41 PM: "Information about the McNeil Consumer recall of certain products at @McNeilRecall"

In both these posts, Marc refers people to the NEW @McNeilRecall Twitter account, which was started at 2:48 PM on January 15, 2010.

The FDA letter to McNeil was dated January 15, 2010. It probably arrived at McNeil in the AM.

So, was this a failure to communicate as suggested by the Times? Did J&J/McNeil falter in its communications in this age of Twitter instant communications?

Well, it did act quickly to set up the @McNeilRecall Twitter account and to post information there and in the @JNJComm account. But, as the New York Times article states, the JNJBlog does not mention the recall.

But communication is NOT the be all and end all of crisis management; ACTION is!

“This is an instance where behavior is more important than communications,” said Stephen A. Greyser, a professor emeritus of marketing at the Harvard Business School, who wrote Harvard’s original case study on Tylenol in 1982. “Communications and good public relations can be very helpful, but it can’t overcome bad behavior.”

Let's apply that maxim to the new world of corporate communications and point out that well-planned and executed use of social media by pharmaceutical companies cannot take the place of good behavior and cannot overcome bad behavior. McNeil should have taken action much sooner by FIRST addressing the problem -- FDA said it did not -- and THEN by communicating to consumers about its actions. "The F.D.A.’s charges of bad behavior have not yet been proved," said Greyser, "but they were serious enough that the company should be more forthright about what its own investigations showed."

Friday, January 15, 2010

If You Can't Beat the Regulators, Sic 'Em on You Competition!

In his latest post to DTC Perspectives Blog, Chairman Bob Ehrlich suggests that the Congress should regulate all health advertising and not just single out Direct-to-Consumer (DTC) advertising by drug companies (see "The Inequality of DTC Regulation").

"Congress, as part of a final health reform bill should give FDA or another part of the federal government jurisdiction over health claim advertising," says Ehrlich. "Americans are wasting precious health care dollars on products that do not work as advertised and potentially dangerous."

I agree. Ads that promote products that "don't work as advertised" and that are "potentially dangerous" SHOULD be regulated. But isn't that what the Federal Trade Commission (FTC) is for?

It's strange for someone who has argued against stricter regulation of the drug industry to now suggest that we create a new regulatory bureaucracy when we have all the bureaucracy we need right now. The only reason I can think of is that Rx drug DTC marketers are getting blasted by the competition. What better way to beat them than bring out the dogs?

All I can say is, be careful what you wish for!

Thursday, January 14, 2010

Why is GSK Making a New Movie About Obesity? Hint: It Doesn't Like the Old One!

By now you probably have read about GSK's announcement that it will finance a NEW “hard-hitting” documentary about eating (see "Alli Marketer (GSK) To Produce Documentary Film on Eating"). [OK, it's not about obesity per se, but I expect to see a lot of fat, even obese people featured in the movie.]

An Academy Award-winning director will be named on Jan. 25 at the Sundance Film Festival. I've asked to be invited to that Sundance announcement (see "GSK: Please Invite Me to the Sundance Panel & Screening of Your New Alli Inspired Documentary Film"). I am still waiting for GSK to make an offer.

In case you don't know, GSK markets Alli, the over-the-counter (OTC) weight-loss drug with the "Oops, I pooped my pants" side effect (see "Alli Newspeak: Oily Spotting is 'Treatment Effect'"). Does that mean the film will be a blatant promotion for Alli? Not at all, says Rachel Ferdinando, a GSK marketing executive.

“The filmmakers can make a decision about whether Alli is important,” she said. “We want it to be entirely transparent; we want it to have integrity. It’s a fantastic outcome if people are simply more educated.”

Then why should GSK spend money on a new film when it was a major sponsor of a 2006 documentary on obesity produced by PBS: "Fat: What No One is Telling You"? This film has high integrity -- it was narrated by Meredith Vieira, the well-respected co-anchor of the NBC News’ TODAY show. "Fat" is also a very popular film according to social media rankings at NetFlix.

I watched "Fat" over the weekend with my family and we enjoyed it very much. Amazingly, even my son watched it till the very end - that says a lot because it competed for his leisure time with the video game "Call of Duty 4: Modern Warfare."

One thing I noticed about "Fat" was its nearly total lack of interest in mentioning medication as an option to treat obesity. I think it vaguely mentioned "pills" once. Instead, it focused a great amount of time on gastric-bypass surgery. As one NetFlix reviewer said "Its like an infomercial for gastric-bypass surgery, from the company that thrives on gastric problems (Tums, Tagamet,et al.)"

It's a stretch to believe that GSK would be happy with all the attention "Fat" paid to the surgery solution because it makes money from Tums.

In fact, I believe that GSK is sponsoring a NEW documentary on obesity BECAUSE "Fat" spent too much time on the surgery solution -- one of the main characters of the film had the surgery (Rocky, a teenage boy) and lost 140 lbs. We all felt happy for him as the documentary ended with Rocky walking to school with a smile on his face. Gosh, I was ready to go out and get myself some surgery after seeing that!

I predict that GSK's new movie will have practically ZERO to say about gastric-bypass surgery and definitely will not feature any surgeons as did "Fat." It may not mention Alli by brand name, but I am SURE it will mention the "miracle" and "promise" of new medications, including over-the-counter medications. But it will warn viewers about "miracle cures" they may see available on the Internet and suggest that they look for reputable products approved by the FDA (Alli ads emphasize that Alli is the only OTC weigth-loss product that was approved by the FDA).

So that's how a pharmaceutical company creates a "non-marketing" film to market a brand name drug. Time will tell if I am right.

P.S. This illustrates the problem with "unrestricted" grants, which is how GSK sponsors these films. Even though GSK can say it has no editorial control, if it doesn't like the result it is not likely to give another "unrestricted" grant to the film producer. Sorry, PBS, no grant for you this time! The grant for the NEW film goes to the Creative Coalition, a nonprofit social and political advocacy organization backed by prominent entertainers like Alec Baldwin, Tim Daly and Susan Sarandon.

Wednesday, January 13, 2010

2009 in Images from Pharma Marketing Blog

What better way to look back on the state of pharmaceutical marketing in 2009 than through the best cartoons, data charts, and other images from Pharma Marketing Blog?

I've put together about 35 of my favorite Pharma Marketing Blog images with some written commentary about each image and the date of publication in the following album, which can be viewed as a slide show. Enjoy!

Creative Pharma Packaging Design: Where Is It Needed?

Guy Mastrion (@gmastrion) over at Pixels & Pills Blog took offense when a colleague "bemoaned the conservative design of most Pharma packaging" and said it was "inevitable since Pharma was a 'Creative Ghetto.'" [See "Breaking Out of the Creative Ghetto."]

Now, you know, whenever someone mentions creativity and pharma or pharma marketing in the same sentence, I get out my blogging pistol.

When ads like those for Rozerem win awards for creativity but do not help ROI, I am especially annoyed (see "Rozerem Ads Dis Lincoln, Show Beaver", "MM&M Award Winners Announced at Gala NY Event!", and "Another Award for Rozerem! This one...not so good.").

But creativity in package design? Guy throws out a challenge to come up with something better than the traditional pharmacy pill bottle shown in its ghetto habitat in the photo on the left/above.

First of all, consumers do not buy prescription drugs like they do packaged goods. I don't walk up and down drug store aisles to chose my diuretic. Packaging, therefore, plays no role whatsoever in the process of fulfilling my prescription.

However, there is an area where packaging plays a role in pharmaceutical marketing: free samples given away at doctors' offices. I contend that there is much creative thought that goes into the design of these packages (ie, "starter kits"). You won't see any awards, however, for creative starter kit designs.

If you want to see creative packaging, you should look at over-the-counter meds, especially those that used to be branded drugs like Alli. These are placed in prominent positions on drug store shelves with snazzy point-of-sale displays and packaging (see "I Opt-Out of My alli Challenge!").

So, don't bemoan pharma package design -- where it counts, package design is an investment that pharma makes. Whether it is good design or not is another matter.

Tuesday, January 12, 2010

If Social Media for Pharma is like Space Exploration, How Far Will It Go and How Long Will It Take?

My Twitter pal Jonathan Richman (@jonmrich) just tweeted this:

"Social media for pharma is like space exploration is today: you can't go far now, but you do it in order to be ready for tomorrow"

I love analogies and have even used one of my own in the context of explaining how pharma is approaching social media. See "A 'Hubble' View Into the Pharma Cosmos" where I suggested that somewhere in the vast cosmos there is a pharmaceutical industry and an FDA similar to ours, with one difference: that pharma industry has learned how to truly use social media to engage and have "human" conversations with patients.

Back to Jonathan's analogy. In response, I tweeted "A human hasn't walked on the moon since I was in graduate school! R U implying that is fate of pharma social media usage?"

So far the best space exploration we've done is to send robots to planets and analyze what is found there. That's equivalent to pharma marketers lurking in social media sites and analyzing what they find there.

Space exploration, like social media, requires that humans actually participate in the adventure, not just send in the robot clowns!

If pharma's use of social media is like space exploration, then I don't expect much human participation in social media until more than 30 years have elapsed.

Just some random thoughts.

Monday, January 11, 2010

Pharma Marketing vs. Healthcare Communication

I was interviewed by phone this weekend about the reputations of global pharmaceutical companies. The interview was sponsored by a company that is trying to remake its image in the US market.

I was asked to rate several companies on a number of attributes that impact their reputations. These attributes included how each company promoted access to its medicines (eg, patient assistance programs), its ethics, transparency, innovation, and how well it listened to patient needs.

At one point I was asked my opinion about a tag line that the sponsor company was testing. It included the phrase "healthcare company" as in "A global healthcare company...yadda, yadda, yadda."

Whenever someone refers to a pharmaceutical company as a "healthcare company" the hairs on the back of my neck (where I still have some hair) rise up. This often happens when I speak to agencies that do consulting work for pharmaceutical companies and talk about "healthcare communications" when they actually mean pharmaceutical marketing.

Are pharmaceutical companies healthcare companies? Should we replace "pharmaceutical marketing" with "healthcare communications?"

The way I see it, pharmaceutical companies are NOT healthcare companies because most pharma companies do NOT deliver health care and do not collect information directly from patients for the express purpose of delivering health care and processing healthcare data. If they did, they would be subject to HIPAA privacy regulations. Pharma companies have rightly denied that they must obey HIPAA regulations precisely on the grounds that they are not healthcare providers (ie, delivering health care).

Thus, the pharmaceutical industry is to healthcare as the defense industry is to warfare. Just as the defense industry provides weapons to warfare delivery organizations (eg, armies and navies) to fight wars, the pharmaceutical industry delivers weapons (ie, drugs) to healthcare providers (eg, doctors) to fight diseases and improve people's health.

Anyway, I thought the analogy was useful for explaining why I did not like a pharmaceutical company tagline that referred to the company as a "healthcare company."

Maybe, however, pharmaceutical companies will someday evolve to become healthcare companies by merging with, say, hospital systems or managed care organizations. Just a thought.

Regarding "healthcare communications" vs. "pharma marketing" -- although I resolved the "healthcare" vs. "pharma" part, the relationship between "communications" and "marketing" is a bit more complex. If you believe "communication" is a one-way flow of information from a source to a receiver, then "marketing" may be said to communicate. But these days, communication is taking on a new meaning: two-way conversation where the receiver can become the source and vice versa. And that's something pharma marketing has not yet mastered.

BTW, "healthcare communication" may be considered a euphemism for "pharmaceutical marketing." I love this "HotForWords" X-rated video explaining euphemisms, even though it does not include "healthcare communication" as an example.

Friday, January 08, 2010

Do Social Media Apps Improve Health Care?

Sometimes evangelists get carried away. That may be stating the obvious, obviously. But often we do not realize this when we listen to evangelists. You only need to look at the presenters at the November, 2009, FDA hearings on the Internet to see social media evangelists in full regalia (see "Industry Groups will Eat Consumer Advocates' Lunch at FDA Social Media Public Hearing").

Not that there's anything wrong with evangelism per se. But sometimes pharma/healthcare social media evangelists get carried away. Today, for example, there was a discussion in the #hcsmeu Twitter group (see discussion topics here) about Web 2.0 changing the delivery of health care. The discussion soon morphed into declarations that social media improved health care.

This belief that Web 2.0 can improve health care was also the subtext of many presentations at the FDA hearings. I could see the FDA people scratching their heads because little actual evidence to support that idea was presented. Sure, there was evidence that consumers used the Internet to find health information. But there was no evidence that Web 2.0/social media tools actually improved health outcomes. If there is any evidence of this, I'd like to see it.

Let's get back, however, to the delivery of health care rather than the improvement of health care. The two are not equivalent nor mutually exclusive. You can, after all, have efficient delivery of bad health care! In fact, the pharmaceutical industry argues that if it weren't for them, social media would actually enhance the delivery of bad healthcare information (and by faulty logic extension, bad health outcomes).

The point I am making is that when we speak of the benefits of social media in the healthcare arena, we need to back up our beliefs with scientific evidence, especially if we are trying to make a point with the FDA.

Next week, I will be interviewing C. Peter Waegmann, Vice President of mHealth Initiative Inc., about the potential impact of moblie phone applications on the transformation of health care (see "How Will mHealth Change Healthcare?"). Mobile apps are in the same category as are Web 2.0 apps -- an advanced electronic information delivery device. But Mobile is like Web 2.0 on steroids -- your mobile device knows where you are, can take a picture of your bumps and bruises, listen to your heatbeat, and soon, maybe even measure your blood pressure! It's definitely a contender for improving healthcare delivery, maybe even improving health outcomes.

But I am not the evangelist; that would be Peter, who is an international leader in health informatics with a special interest in electronic patient record systems, standards, networking, mHealth, and the creation of the national information infrastructure.

What's Your Opinion About Branded Patient Support via Twitter?

This survey asks how effective Twitter can be in carrying out each of the following patient support activities/communications:
  • Drug/device safety alerts (eg, drug recalls, medical device malfunctions, emerging safety issues)
  • Prescription management, including pharmacy refill reminders
  • Daily health tips from authoritative sources
  • Publishing disease-specific tips
  • Clinical trial awareness & recruitment
  • Enhancing health-related support groups (e.g. buddy-systems for depression)
  • Providing around-the-clock disease management
  • Patient-sharing of health-related experiences
  • Issuing dietary/lifestyle tips
  • Delivering adherence and compliance messages
Take the Survey

Please take 2 minutes to answer this survey about how effective Twitter can be in carrying patient support activities/communications. Take the survey here.

You will be able to see a summary of up-to-date de-identified results upon completion of the survey.

Results of this survey may be summarized in an issue of Pharma Marketing News.

Your comments are confidential (anonymous) unless you specifically provide your contact information at the end of the survey and allow us to attribute comments to you personally.

Thursday, January 07, 2010

GSK: Please Invite Me to the Sundance Panel & Screening of Your New Alli Inspired Documentary Film

According to the New York Times, "GlaxoSmithKline is getting into the movie business, pursuing an unusual and most likely controversial strategy to increase interest in a weight-loss drug." That drug, of course, is alli. "Glaxo, the pharmaceutical giant behind Alli, an over-the-counter weight-loss product, has decided that a good way to educate Americans about obesity — and increase sales of Alli — is to finance a “hard-hitting” documentary about eating" (see "Alli Marketer (GSK) To Produce Documentary Film on Eating").

Rachel Ferdinando, a Glaxo marketing executive, summarized the film as “the ‘Inconvenient Truth’ of mindless eating,” with the story taking a “behind-closed-doors, fly-on-the-wall” approach that highlights unhealthy relationships people have with food.

Fat boy Jeff Garlin of “Curb Your Enthusiasm,” will appear on a panel at the Sundance film festive to "promote Glaxo’s recent study findings about eating habits and talk about ways for the entertainment industry to get more involved in reducing obesity."

GSK, I know it's short notice, but can you please send me to Sundance and get me a ticket to this panel discussion?  All expenses paid, of course. Also, when the film is produced, please don't forget to invite me to the New York screening -- I assume it will be screened in NYC. Centocor forgot to invite me to the screening of its documentary film "Innerstate" and they were sorry! (see "Innerstate Private Screening: Philadelphia Style").

Japanese Cloth Company Trumps Merck & Pfizer in New Drug Approvals

With regard to new drug approvals in 2009, "Pfizer and Merck were among the big names that struck out for the year," says Peter Landers over at the WSJ Health Blog. Companies that did NOT strike out were four Japanese companies, including Teijin, a major textile maker!

I was inspired by this story to create this cartoon:

A note about Godzilla (from wikipedia):
Godzilla is one of the most recognizable symbols of Japanese popular culture worldwide and remains an important facet of Japanese films, embodying the kaiju subset of the tokusatsu genre. He has been considered a filmographic metaphor for the United States, as well as an allegory of nuclear weapons in general. The earlier Godzilla films, especially the original Godzilla, portrayed Godzilla as a frightening, nuclear monster. Godzilla represented the fears that many Japanese held about the nuclear attacks on Hiroshima and Nagasaki, and the possibility of recurrence.

As the series progressed, so did Godzilla, changing into a less destructive and more heroic character as the films became geared towards children. Since then, the character has fallen somewhere in the middle, sometimes portrayed as a protector of earth and monster island (and japan) from external threats and other times as a bringer of destruction. Godzilla is also the second of only three fictional characters to have won the MTV Lifetime Achievement Award, which was awarded in 1996.

Wednesday, January 06, 2010

A Common Goal of Research and Marketing: Fool the Doctor

I once believed that pharmaceutical research (part of R&D) was the "bright" side of the pharmaceutical industry and that marketing was the "dark" side (see "God Bless R&D, but Marketers May Go to Hell!").

Then, as so often happens, some pharmaceutical company does something stupid like rigging clinical trial end points to benefit marketing (see "Pharma R&D Succumbs to the Dark Side").

Pharmaceutical companies may be rigging clinical trials in another way: by carefully recruiting patients who are most likely to benefit from the treatment. New evidence in support of this "dark" side of R&D is presented in the latest issue of JAMA.

In the article, "Antidepressant Drug Effects and Depression Severity: Patient-Level Meta-analysis"; JAMA. 2010;303(1):47-53 (doi:10.1001/jama.2009.1943), the authors find that antidepressants are no better than placebo for most depressed patients (ie, those with mild, moderate, or "even severe" baseline symptoms; see chart below; click on it for an enlarged view).

"What makes our findings surprising," say the authors, "is the high level of depression symptom severity that appears to be required for clinically meaningful drug/placebo differences to emerge, particularly given the evidence that the majority of patients receiving ADM [antidepressant medication] in clinical practice present with scores below these levels."

What about all those clinical trials trials that "prove" effectiveness? It turns out that to be eligible for these trials, patients must have pretty high depression scores (HDRS greater than 18). These are precisely the patients most likely to benefit from treatment. "Such cutoffs," note the authors, "can be expected to exclude nearly half of all patients who meet diagnostic criteria for MDD [major depressive disorder]."

But it is not likely that marketers of antidepressants point this out to physicians, especially not to general practitioners who often prescribe antidepressants.

As the authors note: "This important feature of the evidence base [lack of effectiveness in all but the most severe cases] is not reflected in the implicit messages present in the marketing of these medications to clinicians and the public. There is little mention of the fact that efficacy data often come from studies that exclude precisely those MDD patients who derive little specific pharmacological benefit from taking medications."

I'm wondering about other drugs -- Viagra, for example. How were those clinical trials designed? See "Pfizer's Erection Hardness Meter" for more about that!

Marketing's Right Message to Right Person at Right Time Mantra

How many times have you heard the phrase "Deliver the RIGHT message to the RIGHT physician/patient/whatever at the RIGHT time!"? Too many times, I'm guessing.

Let me call it the "RMRPRT" strategy.

Usually, to implement the RMRPRT strategy you need good segmentation based on the interests of the person who you intend to send the message to. For physicians, you might segment them based on therapeutic specialty, how often they write scripts, which products they often prescribe, etc. Segmentation could be based on one or all of these things. Then you have to compose multiple messages appropriate for these segments.

It seems like a good marketing strategy, but is it really?

First, where's the data that supports the benefit of deploying the RMRPRT strategy? If you have it, please let me see it. What I'd really like to know is whether or not the increased ROI offsets the cost of doing the segmentation and creating the different messages. If more and more messaging is done by non-personal means (ie, Internet), the cost per message is so low that it may not make sense to go overboard with segmentation and targeting.

Anyway, I'm thinking that this analysis is not routinely done by pharma marketers.

I know it's not done by marketers in other industries. For example, I just got an email message from DeerPark offering me $2 off a case of water (I get monthly deliveries from DeerPark). I have ordered cases of bottled water before from DeerPark. So I guess I am the right person to send this message to. But wait! Wouldn't it be better to send this message to clients who have NOT ordered cases previously? Isn't that the "right" person? Or maybe DeerPark gives those people an even bigger discount than they offer me. It would be a bummer if I ever discovered that DeerPark offered a better deal to someone else!

Don't get me started about the "right time" issue. I mean, how does DeerPark know when I am thirsty? Heck, they are sending email which I may not even read for hours or days after it's delivered! I could even be at my local bar enjoying a Guinness!

Here's another one. I recently ordered a futon from Now, when I visit websites I see ads for Futons from Obviously, some kind of behavioral targeting has gone awry! Hello! I already ordered the futon!

Do you think this sort of thing happens when pharma marketers try to deliver the right message to the right physician at the right time? Just wondering.

Segmenting physicians into different groups is something pharma marketers have been doing for a long time -- they are good at it mostly because they have access to all sorts of data about every physician. Recently, however, several states have passed laws restricting access to physician prescribing data. This and other trends may limit the ability of marketers to deliver the appropriate message to physicians.

What about patients? It's much harder to segment the general population based on health data. For one thing, there's the federal HIPAA regulations. It's also much more creepy to receive messages that reveal how much the sender knows about your medical condition.

I don't believe, therefore, that the RMRPRT strategy is appropriate for patients unless they have opted in to receive the information. But that's a problem because few people will opt in to receive information from a pharmaceutical company. Maybe that's why we see so many WRONG messages delivered to the WRONG people at the WRONG time on TV! Call it the WMWPWT strategy!

Just a few random thoughts.

Tuesday, January 05, 2010

Filling the Social Media Void: Shout or Be Shouted At!

Yesterday I posted a critique of Bayer's use of YouTube to present the video "A Discussion of Oral Conception Using YAZ: Risks and Benefits" (see "The Trouble with YouTube: YAZ Case Study").

The trouble comes from the fact that if you don't have other videos in your channel, then competitor videos will be highlighted alongside yours. These "competitors" are often law firms suing your company, disgruntled consumers, or actual brand competitors whose videos are selected on the basis of some Google algorithm.

That is, the message vacuum opened up by this YAZ YouTube video was filled by some techie's idea of relevance rather than the marketer's. Marketers should abhor such a vacuum.

Kevin Nalts (@Nalts) offered a "workaround" in this comment to my post: "It's kinda like the web... can't control it but you can shout louder and hope the truth rises. Also there are 2 workarounds. First, branded channels put your own stuff above related videos. Second- You can buy a featured related video spot targeted to your own video."

Bayer might try this solution: Instead of one long 8-minute video, break it up into 4 short 2-minute videos (the video should have been designed for this in the first place). Then the "related video" column would include all the YAZ videos at the top instead of a law firm's anti-YAZ video.

Is this "gaming" the system by "shouting"? If it is, then it's a beneficial form of "gaming" because it actually may make it easier for viewers to digest the message in short bites rather than one big gulp.

"Shouting," however, is not proper social media etiquette. What is shouting any way? IT COULD BE USING ALL CAPS IN TWITTER POSTS. Maybe it's using all CAPS in Twitter posts. It could be using all CAPS in posts made to Twitter. Or it could be repeating the same message over and over again as I just did.

I don't think Nalts meant this when he mentioned "shout louder." He meant populating the space with more of your messages than the other guy. Again, something frowned upon in the social media space.

My suggestion is that pharma marketers ENCOURAGE conversation even if it means critics SHOUTING at them.

My fear is that if pharma marketers are not going to encourage conversation, then their only alternative is to fill the vacuum by pushing out their own messages. If this is what the industry is headed for, then it will be marketing as usual.

Just a thought.

Monday, January 04, 2010

Hire Me to Speak to Your People. Cheap!

Over the past several years, I have quietly worked with a few pharmaceutical companies to give them advice. Usually, I have been asked to make a presentation about the use of the Internet by pharmaceutical marketers.

I never asked for nor received any money to do this. But recently, I have asked that a donation be made in my name to a charity, especially one that is a favorite of the employees of the pharma company that invited me in to speak.

In October, 2009, I was invited by Dennis Urbaniak, Vice President Innovation and New Customer Channels at Sanofi-Aventis, to speak to S-A marketing teams about social media. About 50 or so people turned out to hear my opinion.

Dennis arranged to have S-A donate $2,500 in my name to the Somerset County (NJ) United Way (see letter below). Thank you Dennis and S-A!

Of course, I could have used that $2,500 to buy my new Samsung LN52B750 52" 240Hz 1080p Full HD LCD HDTV and HT-BD3252 5.1 Channel 1000W Blu-ray Home Theater System! But, I suspect that the United Way has a much better use for the money.

How about you? Why not start out this New Year by inviting me in to speak to YOUR people?

P.S. This offer is valid only to major pharmaceutical companies located in the NY-NJ-PA area. Travel expenses may apply. May not be combined with any other coupon or special offer.

The Trouble with YouTube: YAZ Case Study

Pharma marketers are being urged to use social media to reach their audience. High up on the list of recommended social media sites is YouTube, where many pharmaceutical companies have launched "channels" and uploaded videos. Among the first to do so was Johnson & Johnson, which has its JNJhealth channel. It's very nicely done.

The problem is that you cannot control what other videos may be highlighted by YouTube when your video is played OUTSIDE the channel. Let's look at the YAZ Birth Control's Channel as an example. You can find it here. It looks like this:

It looks fine in this context. But if you click on "View comments, related videos, and more," you leave the channel and see the video as a "Generic YouTube Video" as shown below:

Now you can see all the "Related Videos," many of which are from law firms suing Bayer and spoofs of YAZ TV commercials. Even though Bayer has turned off comments, it cannot prevent viewers from seeing these related videos.

Maybe that's OK with Bayer. It has a legal obligation to air corrective ads, but I am not sure this is part of that obligation (see "YAZ Commercial Yanked from TV, But Not from YouTube").

There is a link to the YAZ Birth Control Channel on the US YAZ Web site. Even with that link, the video has been viewed only 412 times and there is only one subscriber to the Channel -- me!

The YAZ Birth Control Channel (aka "YazBirthControlPillDiscussion") looks like it is designed for only one purpose: an in-depth "discussion" of risks and benefits, which I think it does adequately (although 8 minutes is beyond many people's YouTube attention spans).

Why Bayer chose to put this video on YouTube, where it must compete with negative videos from 3rd parties, is a mystery to me. It's not getting many views, has no subscribers (except me), and has no promise of future updates. Why not just keep the video on the product web site?

My advice to pharma marketers: Unless you intend to promote a real discussion or upload a series of videos that will enhance the value of your YouTube channel, stay away from YouTube!
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