Friday, December 02, 2016

Can This Work for Pharma? The Continual Quest of Creative Advertisers

PM360 magazine is asking its readers find marketing campaigns and tactics used by consumer packaged goods, retail, and other industries to give pharma marketers some fresh ideas. Here's what one ad agency SVP Executive Creative Director came up with as and example of how pharma can "push the boundaries":
In terms of creepiness, this campaign has nothing over some creepy pharma campaigns I've seen (see, for example, my "Gallery of Scary Pharma Industry Advertising").

According to the Creative Director who submitted this example to PM360, Australia’s Transport Accident Commission’s "visually and emotionally jarring approach to the problem of connecting with the public about road safety was unique and inspiring. Rather than educate people on the tragedy of auto-related deaths with a metaphor or visual of a mangled person, they reframed the problem by looking broader and closer, and by thinking younger."

But these and other "fresh [creative] ideas" are not really new to pharma or they just won't work for pharma. Let's examine each one.

Wednesday, November 30, 2016

FDA Compliant Diclegis Instagram Promo by (Good) Emily Maynard Johnson Can't Compete with (Bad) Kim Kardashian's Violative Post

About 22 weeks ago, Emily Maynard Johnson, who appeared on ABC's The Bachelor and The Bachelorette, posted the following Diclegis promotion to her Instagram account:


I assume you've noticed that all the ISI (Important Safety Information) and side effects are mentioned either through links or, more importantly, within the post itself (you have to scroll down to see it).

This is in contrast to Kim Kardashian's Diclegis Instagram promotion that made news last year. That ad drew a prompt warning letter from the FDA to Duchesnay USA, which markets the drug, because the post did not mention nor did it link to any ISI or side effect information as required by FDA regulations (for more on that read "OMG. Kim Kardashian Shills for Pharma! No Worry - No Side Effects!" and "Celebrities + Social Media").

There are a couple of other important differences between these two celebrity Instagram endorsements/ads.

Monday, November 14, 2016

The Evolution of the Written Word in the Social Media Information Age

I started writing about the drug industry – specifically the commercial side of the industry – in 2002 with the publication of the first issue of Pharma Marketing News. At the dawn of the social media age in 2005, I started writing Pharma Marketing Blog and in 2008, I started tweeting.

By the end of 2016 I will have written over 4 million words, which is equivalent to eighty (80) average length non-fiction books! BTW, I also co-authored a book ("Socialize Your Patient Engagement Strategy").

Here is the breakdown of the current stats relating to my Internet publishing activities over the years:

Pharma Marketing News (started January 2002)
  • 639 articles 
  • Over 1.2 million words (1800 words per article
Pharma Marketing Blog (started January 2005)
  • 2393 posts
  • Over 2.3 million words (554 words per post)
 Pharmaguy on Twitter (started March 2008)
  • Over 26,000 tweets
  • Over 0.5 million words (21 words per tweet)
Do you see the trend?

Friday, November 11, 2016

FDA Hears Results of Two Different Off-Label Surveys of Consumers at Recent Public Hearing

At the recent Part 15 FDA hearing on off-label promotion (see here) results from two different consumer/patient surveys were presented. The first was presented by John Mack (i.e., me), Editor of Pharma Marketing News (PMN) and the second was presented by Dr. Doris Peter, Principal Investigator, Best Buy Drugs Project at Consumer Reports (CR).

The PMN survey was administered by inVibe Research, which collects responses via automated, voice-response surveys. Fifty-on respondents were reached via a network of patient community partnerships. These included 40 patient advocates, 20 chronic condition patients (diabetes, fibromyalgia, arthritis, CHF, etc.), and 9 caregivers.

The Consumer Reports survey was done by random-digit dialing so that the 1,011 survey respondents are "demographically and geographically representative of the U.S. population."

Thus, an important difference between these surveys is the first is patient & patient advocate specific whereas the second is generally consumer specific.

Let's compare the results of these two surveys.

Thursday, November 10, 2016

What is "Truthful and Non-misleading?" That is the Question FDA Must Answer to Allow Off-Label Communications by Pharma

Yesterday, I attended and presented at FDA's Public Hearing on drug company communications regarding unapproved uses of drugs. My presentation had to do with off-label promotion directed at consumers and patients (find it here on Slideshare).

Just a few takeaways.

The phrase "truthful and non-misleading" was mentioned several times during the meeting, including by PhRMA (read "BIO #Pharma Industry Offers Its Own Set of Off-Label Communications Principles") and the Washington Legal Foundation (WLF).

In its testimony (here), the WLF said:
"Starting in the late 1990s with the Washington Legal Foundation cases, courts have consistently upheld corporations’ and their representatives’ First Amendment rights to communicate truthfully and non-misleadingly about the effects of their products. Courts have held that such a right is not limited by FDA approval of the use that is under discussion. Rather, the limiting factor on a company’s speech is a classic First Amendment test: whether the communication is false or misleading. Therefore, the FDA may only restrict health care companies’ speech regarding both approved and off-label uses if it is untrue or misleading to the listener. This test is grounded in both the Constitution and sound public policy. Pharmaceutical and medical device companies and their representatives possess the same rights to free speech under the First Amendment as other individuals, and patient care is strengthened by increased access to truthful information and innovation regardless of its origins." 
But defining what is true and non-misleading is difficult as many presenters noted.

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