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A New Reality in DTC Advertising?

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The last few months, I've been deeply entrenched in "Execution" for an important client. So needless to say, I've been thinking A LOT about what it takes to move from strong strategy to superb execution, and more specifically, what it takes to achieve what I call "High Return Execution" (HRE).    Look for more thoughts on HRE in the upcoming weeks... (And my sincere apologies for the resulting lack of blogging and staying connected with many of my friends' blogs these last few months)

Today, I want to share a personal experience.  Last week my team led an advertising shoot for a prescription product's new multi-channel campaign we are intimately involved with.  There was much to feel good about - the creative idea tested very well and is strong. We also had a terrific creative and production team, a wonderful photographer who we've all worked with before, and we were shooting in a venue that turned out to be magical...not to mention the beautiful picture- perfect, dry sunny days ... [How can you  complain about spending two days on an unspoiled 200 acre ranch in northern California?]

But as I flew home from the shoot, reflecting upon the previous few days, I kept feeling there was something even more special ... something that I rarely feel after shoots ... and then I realized ...

print shoot at ranch print shootOur work included real patients and in some cases their families as well.   We shot three different print executions using three different patients.  In one case, the mom brought her daughter who was not only proud of her Mom, but also proud to be photographed. 

You might ask, what's the big deal?  As everyone knows, so often in branded consumer and healthcare advertising -- TV, print, web etc., ads are created using models or professional talent.  Certainly, using real patients or ‘real people' adds a great deal  of complexity and tension, as these shoots require much prep and planning, and have a sizeable cost ... Using real patients means you're never quite sure until ‘it's a wrap' -- that you have captured the idea you are trying to communicate ... It also takes more time and requires special artists and production types to work with real patients...

We decided to use real patients because the idea behind our ‘first person' campaign  ‘demanded' authenticity.   Lest you dismiss this as just a current buzzword, keep listening. These are real patients who are living their lives to the fullest extent they can, and genuinely grateful for their prescription product's ‘contribution' to their improved health and QOL. Additionally, these patients were willing to step up and be photographed about a medical condition that is embarrassing to most and difficult to manage.  These patients weren't participating in these ads because they were going to get rich (hardly), they were participating in my client's campaign because they are thrilled to be living their lives in a fuller way -they had reached a milestone so to speak, and wanted to give back. They each stepped up in the hopes of leading others like themselves to try to get the right help for themselves (It may be this prescription product, or it may be another)... to help spread the word, and bring hope and attention to a medical condition that gets little attention otherwise...

Each patient joined in the production process...they were not just models that showed up for their ‘job'; they were on mission, ... tasked to rise to the challenge of being center stage and photographed...something that none of them had ever done in their lives...and in itself a huge personal risk.  There were times that you could feel the wheels in their heads spinning, "this sounded like a good idea when I was in the comfort and safety of my home, but now that I'm here, this is more than a little overwhelming and scary ..."

As a result, everyone on site joined in to support these patients to be able to do their personal best ... It was also a continual reminder to each of us why we were at the shoot ... certainly to capture DTC advertising and patient communications for our client, but it was more than that ... we were there to shoot a new campaign that would  help the many patients with this condition that are still not feeling their best ... to help spur and initiate awareness, education and dialogue so that these patients can participate in their own health decisions and have more enlightened discussions with their doctors ... The vulnerability was gripping.  I'm confident that we at the shoot will not be the only ones to respond.

It leaves me wondering what the increasing use of using real patients will mean for "direct to consumer/patient" advertising and relationship marketing in the future?  Are we witnessing the birth of a new standard that will demand real patients who are advocates for themselves and others? ... Who make a difference each day by being true participants in their health? Will consumers be touched by their 'less than perfect' delivery as actors and models?   

I suspect this trend is here to stay. The pressure is on to "come clean" when the ad suggests that it's a real patient and it isn't (See the Abilify example).  There's no faking ‘real patients' who are actively participating in their health; time will tell what impact they will have on our industry going forward--and how they potentially transcend  advertising and marketing...

My heartfelt thanks to the three patients who made a choice to join us this past week.  I learned with each conversation, and I hope they learned a little too.  I also made three new friends... :-)

See other examples of current DTC Print Ads Using Real Patients, click on image below

What Would A Pharma Marketing Champ Do? 9 Imperatives for 2010

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This is the final post of a four-part series.Mohumad Ali Champion

What Would Steve Jobs Do? 

What Would Google Do? 

What Would Jake and Rocket Do?

These are champs.

What would a 'new marketing' champ do in Pharma and Healthcare?

Here are 9 imperatives I see for Pharma Marketers as we enter 2010 and a new decade:

  1. Adopt human-centered thinking across everything you do. Both Steve Jobs and Google share a relentless focus on knowing and pleasing their core customer - the consumer. No detail is ignored if it brings value. Importantly, these champs don't think of consumers sporadically or when it's convenient, but in every decision and action they take.  The customer experience is front and center from beginning to the end.

    Pharma and Healthcare marketers: are patients at the center of everything you do? Really? As Steve Jobs might ask, are you taking full responsibility for your patient/e-patient user experience? Are you thinking about every touch along the treatment pathway, that is no longer a straight linear line, but made of multiple touches, information and influences often hitting at once and with circular repetition? (You may also want to read: Is Your Brand Patient-Centered? 5 Critical Success Factors)
  2. Get outta town. Experience and see what your patients see. What are your patients' challenges? How could you help? How can you insure that learning is turned into action back in the office? Who should 'own' a particular learning or insight and see it through? Pharma and Healthcare Marketers: is listening and learning part of your everyday doings? What are consumers and patients saying about you? your product? your service? What are they saying on twitter? Facebook? patient communities? How are patients rating your brand on sites such as iGuard? (You may also want to read Jonathan Richman's Dose of Digital blog: The Best Pharma Products According to Patients)
  3. Simplify.  Challenge your product and marketing design: Is it simple enough? Simplify your products and services; simplify your customers' lives; simplify your own life...Create simple experiences.  Think about starting a search on Google...or picking up an iPod...Pharma and Healthcare Marketers: During every step of product development and marketing planning: stop and ask yourself: If Steve Jobs was the Product Manager on this, what would he do? Is the design and implementation  of your product/program flawless?
  4. Embrace publicness and openness. Transform your relationship with the public in every quarter of the organization.  You may extend this new relationship in many ways from blogging, interacting with bloggers and e-Patients, participating in twitter or Facebook, customer service and sharing ideas.  Overtime, you may even truly involve customers in the real-time design process for products and/or services...But 'publicness' is much more than having a web site. It's about taking actions in public so people can see what you do and react to it, make suggestions, and tell their friends.  Living in public is a matter of enlightened self interest. You have to be public to be found. Every time you decide not to make something public, you create the risk of a customer not finding you or not trusting you because you're keeping secrets....the more public you are, the easier you can be found, the more opportunities your have...(Read Privacy (and Publicness) by Jeff Jarvis Buzz Machine)
  5. Don't try to control content and distribution, and think about how you can bring your customers 'elegant organization'.  First, think in distributor ways.  Go to your consumer whenever and however you can.  This is still the opposite of many companies who continue to think centralized and want to make consumers come to them.  They spend large dollars to advertise to attract consumers.  Many try to make their home pages into destinations.  In sum, while many internet sites think of themselves as an end--Google thinks of itself as a means.  While many see the job of their home page to take you to where they want you to go, Google sees its home page as the way to get you to where you want to go.  Google distributes itself.  Google enables others to use tools as they wish. Think of your site as 'answers for every question you can imagine'.

    Second, it will also be helpful to think about 'elegant organization' as Jeff Jarvis outlined in What Would Google Do?--Mark Zuckerberg originally coined the phrase to stress that communities already exist... As marketers, entrepreneurs and technologists, we can benefit from these communities by providing them with elegant organization. Help them do what they are already doing better.  Pharma: how can you aggregate and curate useful and valuable content for your patients/ customers? How can you replace focus on mass market with focus on mass of niches? And how can you provide helpful content consistently?
  6. Think mobile. Engage real-time with your customers 24/7. Mobile doesn't have to be just about apps; consider the value of texting, geolocators, and/or the use of quick response (QR) codes for simplification...
  7. Takers may eat well, but givers sleep well. While most will wait for the FDA guidelines to be published for social media and web, some will move forward to listen, learn and to "give as well as to take." There are still opportunities for Pharma to learn, and support patients and their communities, especially if Pharma starts to see themselves not only as products, but as a service, a platform, a means to enabling others. The bottom line: help your patients (and customers) build value. One new example may be the launch of the new Patients Like Me Epilepsy Community in Partnership with UCB. (While UCB is a client, I have nothing to do with their epilepsy business.)
  8. Do one thing really really well--focus on what's most important.  Each champ does one thing really, really well.  Google never loses sight of what search means to their business strategy, and in their continuous focus for improvement of search, it continually spurs other applications and new products/services. Apple never loses site of flawless and simple design for maximum consumer appeal. Jake and Rocket for Life is Good always stay close to their roots of humor and humility. What does your company or brand do really well? Where can you focus resources to continually innovate?
  9. Raise Your Bar. Good isn't good enough.  If you don't think it would pass Steve Job's bar, then don't let it pass yours...Or you can think like Google: being great is a starting point, not an endpoint. But as Steve Jobs says, Stay Hungry. Stay Foolish.
Welcome to the new decade of new-marketing--any other imperatives that you'd like to add or delete from this list? Please do share!


Muhammad-Ali Image: 1976 World heavyweight boxing champion. Photo Source: Frank Tewkesbury/Evening Standard/Hulton Archive/Getty Images

Pharma: Are Guard Rails Useful To Our Social Media Future?

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There's a reason why there was such a great turnout for the Digital Pharma Unconference this week...Hats off to Shwen Gwee, Jason Youner of eXL pharma, and all the speakers and participants. (#DigPharm)

Before I talk about Guard Rails, here are three other good reads from fellow bloggers: Steve Woodruff's I Was There (Digital Pharma 2009), Jonathan Richman's Dose of Digital How Pharma Overcomplicates Social Media, and John Mack's Pharma Marketing Blog: Pharma Social Media Crips vs. Legal/Regulatory Bloods.  Also check out the tools that Fard Jonmar and Jonathan Richman used in their social media workshop. Or Digitas Health Social Media POV given by Sarah Larcker of Digitas.

pharma guardrailsSo what do we mean by Guard Rails? The Wikipedia definition reads something like this:

"Guard rail, sometimes referred to as guide rail or railing, is a system designed to keep people or vehicles from (in most cases unintentionally) straying into dangerous or off-limits areas."

So what does this have to do with Pharma and Social Media?

First, I'd be remiss not to credit Marc Monseau (JNJComm) who used this term in his presentation: "We're doing It and So Can You. J&J's Use of Twitter". Creating 'guard rails' was part of his 7 suggestions to Pharma: 1) Create your business case, 2) Connect SM with other initiatives, 3) Establish your personality--interesting people are followed, 4) Set guides around what you will and won't discuss...guard rails, 5) Gain legal/regulatory support for guard rails, 6) Create processes and tap into existing processes e.g. reporting AE's, 7) Tweet, tweet, tweet. Advice from JNJMore lessons from JNJ (pictures courtesy of Steve Woodruff).  (You may also want to read a great interview with Marc Monseau: J&J On Twitter)

Guard rails can help provide a 'safety net' to Pharma social media tactics and those running them by helping to insure that clear and simple guidelines are set up around certain areas to help frame conversation and engagement, and to keep social media efforts on safe regulatory and legal ground...

Other key takeaways and discussion points from #DigPharm:

Is your brand a lovemark? Is it irresistible to your consumer? Does it provide the right empathy to patients? At the core of every lovemark is RESPECT. How does a Lovemarks compare to a trademark? Trademarks are 'owned' by marketers--Lovemarks are 'owned' by their consumers. (Watch the T-mobile video: "Life's For Sharing")

What are consumers saying about your prescription product? Check out iGuard.org to read patient reviews. Monitor other social media venues.

"A patient is an unwilling customer".  They are 'buying' your medication to help their condition, but they're not happy about the disease/condition that they have, often for life...(courtesy of patient blogger and tweeter: @amblass) This was part of 5 suggestions for Pharma: 1) listen 2) be honest 3) think big- beyond marketing a product 4) a patient is an unwilling customer. 5) be there for me.

"Just like soccer, Social Media is about moving the ball up the field....until we can put the ball in a strategic, favorable position" (courtesy of Fabio Gratton of Ignite Health and Xavier Petit)

BTW, if you're looking for a community to continue the Pharma Social Media conversation, join Shwen's Social Pharmer.

Other recent Pharma conference blogs that may be of interest:

Pharma: Dip Your Toes And Other Tips From DTC Perspectives Conference

Pharma Marketers: A Few Takeaways From the PharmaMed Conference

Pharma: Dip Your Toes and Other Tips From DTC Perspectives Conference

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We're in the midst of conference-frenzy.  Last week I was able to attend day two of DTC Perspective's Fall Conference: Reform & Refocus  (For twitter followers: #dtcfall). Here are some of the key themes that I picked up:

  • dip your toes social mediaDip-your-toes approach. This was said over and over about social media. Get started, and evolve as you learn and your company becomes more comfortable with the effort. (This is also a common theme in Digital Pharma's conference taking place this week. #digpharm)
  • Remember your overall marketing strategy--Before you clarify objectives  for social media and start running with tactics...
  • Give the team TIME. Initiating new social media programs took many more hours and resources than originally planned. And there is always the unexpected...
  • The Internet is for marketing-not just advertising. This also requires a shift in mindset. (Bill Drummy of Heartbeat Digital)
  • Technology is moving oh soooo fast-Mobile, video, ‘smart' advertising using behavioral data, gaming and of course social media are musts to be more than experimenting with in 2010.

During day two, two presentations stood out to me:

Hologic and Greater Than One: How Social Media Can Become Real in Healthcare.  Marnie Rosenberg, Partner, Greater Than One and Mary Pietrowski Director of Consumer and eMarketing of Hologic did a great job presenting four case studies, including a branded YouTube video. This is also where the infamous twitter tweet: "60% consumers don't care who sponsors health info- just want good info, community-value". (Turns out it's based on Infomedics Survey.) They also presented iCrossing data showing that of the online tools and websites, social media is used by 34% to locate healthcare information.

The On Demand Brand (book due out spring, 2010) by Rick Mathieson: Digital to Consumer-- The 5 Top Trends in 2010

  1. Social Networking of course...Regarding video, Rick presented data saying that nearly 50% of US adults say online video is a key way they research DTC drugs. His suggestions for pharma: use Social Media more for event based marketing, keep it social and targeted.
  2. Smart Advertising using behavioral data, but being careful not to target too well or to become invasive
  3. Mobile, especially texting, apps and use of QR codes
  4. Video Games For Health and Advergaming (See my blog covering 2009 Games For Health Conference and PharmExec article Video Games: Key To The Future of Healthcare?)
  5. Augmented Reality. The rules: Entertain, Educate and Engage

Wrapping up the conference, there was a good panel discussion with Pharma Marketers and Industry experts on The Use of Online Video in DTC Marketing led by Raj Amin, CEO, HealthiNation. Monique Levy @monasante also reviewed some recent Manhattan Research data. One of the points she made was that 25% of consumers view video on product.com sites.

Overall, the discussion centered around the big opportunity of video and suggestions to optimize its use e.g.: keep it moving (no more than 2-3 minutes) and tell an interesting story with great content.  Saatchi Wellness talked to their successful rooster campaign and the move from unbranded to branded. Nike was also discussed as a great example of parceling out video info depending on a consumer's interest. They keep initial video short, but enable additional video watching for those who want more info etc.

Any other thoughts?  Overall, day two was a good day!


 

Strong Brand Core--More Core Than Ever?

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This has been quite a year for pharma and marketers:  big market changes and budget cuts, not to mention a continued explosion of noise, with less time to absorb and respond.

As we head into quarter 4, I've been asking myself,

What disciplines would take good care of our brands in this vulnerable moment?


Creativity gives the brand wings.  David Ogilvy is famously quoted, "Give me the freedom of a tight creative brief."  When the strategic core is strong, it serves as a foundation to produce the richest creative that can make your brand soar.  The triangle's three points: meaning to consumers; elegance and balance; and rigorous execution act as foundational questions to help marketers check-in with their brand and test new strategies and tactics. 

My prescription is: mind the strength of your strategic core. 

pilates core strengthThe practice of keeping a strong strategic core has become very popular with consumers in recent years, with rapid growth in both Yoga and Pilates, and now next-generation offers like Barre 3 and PiYo.  The techniques improve condition and balance by building core strength--Checking in with their core before taking any action enables people to move better, feel better, look better, and lead more productive lives.     

In a chaotic world, the discipline to strengthen core strategy and keep it strong is a formidable challenge.   The noise in the marketplace is a din; changes in social media alone in the last 6 months have many marketers in a spin.  As the noise increases with the plethora of new tactics to distract us,  those with the discipline to stay grounded and centered on brand core, to ensure that each tactic is informed by core strategy, will enjoy stronger brands.

How are you keeping your brands' core strong and focused?  

With all the noise and distractions, and little time to stop and think, how are you holding an unwavering stance to power your brands' core?

 

Video Games: Key to the Future of Pharma and Healthcare?

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Full Article Published in PharmExec.com August 5, 2009. 

Everyday new results suggest that health games and virtual worlds bear the potential to be "game changers" by improving education, provoking greater engagement, and engendering positive behavior to enhance health and wellness. 

While more clinical studies are still needed, preliminary results are beginning to demonstrate proof of principle.  In the wake of the 2009 Games For Health conference, the article outlines five factors for why you might start to take health gaming seriously, as well as key lessons consistently described by the speakers, to provide a perspective on what may be involved in bringing Health eGames into 2010 planning and beyond. (For a summary of the two-day event, along with the associated marketing implications of healthgames, see PharmExec guest blogs "The Next Frontier" and "Can Healthcare Games Change the Game of Healthcare?")

Gaming for Health: Five Factors

  1. Games are not just for kids, or teenage boys, but are increasingly played by digital moms and 50+ consumers
  2. Games enjoy broad penetration--in the US, 68% of households play computer or video games
  3. America faces serious health issues that need extra attention e.g., diabetes, obesity, lack of adherence. Games can provide a fun and innovative way to reach new audiences.
  4. Early success stories for health games suggest meaningful public health benefits. Four examples of health games with measurable clinical results are outlined in the PharmExec article.
  5. Serious players are supporting the growth of health games, including health insurers such as Humana, and foundations like Robert Wood Johnson, Annenberg, Lance Armstrong and Sesame Workshop's Joan Ganz Cooney Center.

Bring More to Your Brand's Arsenal

Games for health can provide many benefits to a brand-- from education and entertainment, to improving adherence or training (See Marketing Implications). As you plan for 2010 and beyond, consider these seven lessons for boosting health game development, as presented by this year's Games For Health Conference speakers:

  • Focus on FUN--Keeping up the fun factor takes creativity and insight
  • Provide relevant value through absolute clarity of the target, the desired customer experience, and the unique value proposition
  • Personalize the experience wherever possible
  • Keep it simple. Deliver a guided experience that is easy and doesn't make consumers have to think too much or work too hard.
  • Think 24/7 experience. Consider many channels and platforms
  • Maximize social interactions via sharing, support, and competition
  • Keep metrics and measurement front-and-center

Healthcare games hold huge potential for the pharma industry, by both engaging consumers and improving health and brand outcomes--all in an interactive electronic format that will be an important part of consumers' lives for many years to come...

Games for Health may even represent pharma's chance to leapfrog Web 2.0 straight to Healthcare 3.0...Can you imagine?

What do you think?

Pharma Marketers: Think You Can't Do Moderated Chat?

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Is your brand actively engaging its customers, enabling them to share their stories and opinions, and hear from "other consumers like them"? (In the latest PEW Internet and California Healthcare Foundation study, 68% of all adults ask a friend or family member for healthcare information-second only to asking a healthcare professional at 86%, and 57% of all adults use the internet.) Or are regulatory and AE concerns keeping you from considering moderated chat, even though it could strengthen two-way conversations  and help move your brand closer to building a genuine community?

Asacol, P&G's prescription treatment for Ulcerative Colitis has recently launched a new Community for UC patients to share stories-and share advice.  Asacol created a moderated chat where consumers can share their stories -if they keep it focused on their experience managing UC - diet, travel, telling others, etc. - and do not mention "Asacol" or other drug treatment options by name. (See their Guidelines for submitting stories.)

In the Asacol Community, consumers are encouraged to provide stories or to ask questions.  Content is carefully moderated per the guidelines, but consumers can rate and vote on story content and answers.

To help implement their program, Asacol partnered with Bazaarvoice, a company who provides a framework for capturing, managing, marketing and leveraging authentic user-generated content so that brands can capture and leverage their customer 'word of mouth' asset.  Bazaarvoice offers fully supported, hosted technologies that provide multiple levels of careful moderation. While new to the pharmaceutical industry, Bazaarvoice has provided their products across many other markets and for such key clients such as Walmart and Disney. 

Some of the products they offer within their platform:

The Ratings & ReviewsTMsolution combines technology, services, and expertise to harness customer opinions and help you build a dialog with your customers. (Ratings and reviews have also been shown to have a huge impact on organic search listings.)

Bazaarvoice StoriesTM offers a new way for your brand advocates to share their experiences on your site. This functionality allows visitors to talk about their experiences  without having to assign a rating. It's a great place to build a community for people with similar interests while making your site - or brand - the "destination."

The Ask & Answer TMsolution taps the power of online communities to address consumers' unanswered questions. This direct customer education can increase brand engagement and loyalty. (For addtional learning on the use of Bazaarvoice products, read Lessons from the Bazaarvoice Conference- ClickZ)

Another Pharma company building a two-way community is UCB. Recently, they announced a partnership with Patients Like Me to launch an epilepsy-focused patient community, and will report adverse events to the FDA through round-the-clock surveillance. The biopharma said in a release that the partnership will create "an online, open epilepsy community" in order to "collect, analyze and reflect information received from people with epilepsy, regardless of their diagnosis, prognosis or treatment regimen." The online community is expected to lunch in early 2010. (Medical Marketing & Media)

So it seems that Phrama companies and brands are beginning to move into greater two-way conversations and community-building. As companies and brands become more comfortable with these new platforms, hopefully they can further evolve to giving consumers more freedom to speak about their brands and treatments too... And pharma will see that the number of AE's is small and manageable...(The Myth of Adverse Event Reporting, Dose of Digital)

Hats off to Asacol for launching a community building effort on their branded site! (though the site itself could use some improvement with regard to user experience and graphics)

Other thoughts? 

 

Are Pharma's Hands Tied with New FDA Draft Guidance for DTC?

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fda ties pharma's hands?This week, the FDA issued a 24 page Draft Guidance for Industry presenting risk information in prescription drug and medical device promotion. The draft guidance provides numerous examples of print/tv/video to illustrate FDA's thinking on presenting risk information, and is equally applicable to presenting benefit claims.

However, the draft guidance does not address the unique features of sponsored links, banner ads, the subject line of e-mails to physicians or patients, or any other  social media or internet communications more generally. FDA  says in the Draft Guidance that the agency applies the same principles about risk disclosure in prescription drug advertising  to all promotional pieces, regardless of the medium used.

Overall, the draft guidance is  very consistent with prior guidelines and current industry practices.  Coming on the heels of  recent warning letters, the FDA has taken a 'more vs less' approach, providing concrete examples, but not in the area of web and social media that many of us were hoping for! Some key takeaways:

  1. It's all about appropriate and effective risk and benefit communication; promotion that is designed to achieve a BALANCED risk/benefit presentation. (How often have we heard this before?)

  2. FDA looks not just at specific risk-related statements, but at the NET IMPRESSION- i.e. the message communicated by all elements of the piece as a whole... (Again, this isn't new, but it's repeated throughout guidance.)

  3. Content and format can contribute to a misleading net impression in promotional pieces; numerous examples are provided to help illustrate this. The FDA subscribes to the universal concept of communication and cognitive understanding of risk information which is why the draft guidance addresses both physician and consumer audiences. Additionally, unless specified, the principles outlined by FDA apply to all promotional pieces, regardless of the medium used or the target audience. (FDA has been signaling this in recent interviews for web and social media--"It's not the medium but the message."  Mark Senak's interview with Dr  J Kang)

  4. The reasonable consumer standard used by FDA in evaluating promotional materials is similar to the FTC standard: They will examine reasonableness from the perspective of the group with which the promotion is targeted. FDA, like FTC, takes into account the different levels of expertise of lay consumers and healthcare professionals. However, research has shown that experts (in this case, healthcare professionals) are subject to the same cognitive biases and processing limitations as non-experts. The guidances discusses factors that can affect attention and comprehension. (This was very evident in the FDA Risk Communication Advisory Committee Meeting that I attended back in February 2009. This is still an area with  big opportunity for improvement: 'Less is more; simplify for the consumer')

General Considerations:

  1. Consistent use of language appropriate for the target audience Ie. If benefit claims are presented in consumer friendly language then risk language should also be in similar consumer friendly language and not medical lingo.
  2. Use of Signals (e.g. headlines in a print ad) should be consistent across benefit and risk information; content of signals are important too. FDA is looking for specific and clear signals vs  those that are vague or abstract.
  3. Framing Risk Information with the same terms or with the same degree of specificity as benefit information.
  4. Hierarchy of Risk Information--the most important risk information, including relevant warnings and contraindications, should be placed or stated first...

Considerations of Content

  1. Quantity: As the amount of benefit information conveyed increases, the amount of  risk information conveyed should similarly increase. The amount of information presented is one component that, together with choice of words, color, graphics, voiceover, and other aspects of the piece, can affect cognitive load, the  mental effort required to understand the various components of information in the piece.  This suggests comparable treatment of the risk and benefit information in each piece. 
  2. Materiality and Comprehensiveness: Material facts are those that would influence reasonable consumers (or healthcare professionals) about a product-such as: The relevant properties of a product, appropriateness for themselves or their patients, willingness to accept the risks or burdens associated with using or prescribing a product. 

Considerations of Format

To process information, a person must first pay attention to it. As a general matter, risk and benefit information should be comparably noticeable or conspicuous and able to be read with similar ease ( e.g., comparably legible and understanding)

Print Promotion--layout and formatting factors: 

  1. Overall location of risk information should generally appear in the same parts of the piece as the benefits.
  2. In addition to appearing with or near benefit information, risk information should appear as an integral part of the piece, just as benefit information does. (This is often called "peppering" by regulatory advisers and largely where J&J's Ultram ER got into trouble and received a recent warning letter for their video)
  3. Font size and style that affect the prominence and readability of information
  4. Contrast between text and background should not highlight the benefits more than the risks.
  5. Use of White Space should be similar for risks vs benefits.

Non-Print Promotion

As with print, FDA considers factors such as location, proximity, type size and style, and contrast when evaluating videos or broadcast ads. But the FDA also evaluates other formatting factors such as audio components, motion within the visual component, the juxtaposition of visual and audio components, and duration of exposure.

  1. Textual Elements: FDA provides many recommendations when using SUPERS to insure they are legible, understandable and in close proximity with the claim. In addition, if qualifying information is complex and requires more than one line of text, FDA recommends using other means to convey this information.
  2. In addition to distracting visuals during the audio presentation of risks, the use of even inherently compelling, vivid visuals which may be deemed too inconsistent in tone or imagery that they distract the audience from listening to or processing the risks.
  3. Audio Considerations such as speech quality, pacing, volume and background music need to be comparable during both benefit and risk presentations.

It's important for Pharma Marketers  to keep moving forward without feeling like their hands are tied...and to not let the guidance sap  creativity across communications and media platforms.

The Draft Guidance is open for comment for 90 days after publication in the Federal Register, which has not yet occurred.  This provides an opportunity for proactive leadership, especially if the industry wants to see more dialog around  web guidance.

For more information on a Conference Call and the Ad Hoc Coalition, see the Memorandum drafted by McDermott Will & Emery via Fabio Gratton at ignitehealth blog and eye on fda.

New DTC Ad: Grow your eyelashes!

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I was SURPRISED to see this new DTC print ad by Allergan for  Latisse--the first and only prescription product to help with "hypotrichosis"--another name for having inadequate or not enough eyelashes!

Latisse DTC Print AdWith the economy in the dumps and Pharma and DTC advertising under increasing scrutiny, here's a new print campaign for what might seem like a pretty trivial and 'soft' medical condition. Adding to this is the fact that they are using a celebrity endorsement in their advertising-Brooke Shields- which adds an extra level of scrutiny these days-- and they're advertising to the consumer within the first six months of introduction (I guess their thinking is that this is a safe cosmetic treatment and therefore shouldn't follow the latest PhRMA Guidelines. It contains the active ingredient of the glaucoma drug Lumigan, which is also made by Allergan.). 

They've tapped Brooke with terrific testimonial video and great 'before and after' photos (not retouched of course) demonstrating results at 12 weeks...hoping women will return to see her results at 16 weeks. (Honestly, I can't ever remember ever thinking that Brooke's eye lashes were ever deficient...I do remember her for her stand against postpartum depression which I think was greatly admired by many. ) There's also a fund raising effort for 'make a wish foundation' on the website.

Here's a pure cosmetic play in both look and feel and content-there's no medical information on the website tied to hypotrichosis.  With this current economic climate, can this DTC effort generate a strong ROI? 

Are there enough Women out there willing to embark on a once-daily prescription treatment that will:

  • likely not be covered by insurance
  • need to be taken everyday for 8 weeks before seeing the first results, and up to 16 weeks for full results
  • need to be taken 'forever' in order to maintain the effect 

And since its early days in its lifecycle, there's the assumption of no hidden side effects down the road... (Botox Botulism)

While Latisse brings consumers choice, how do cosmetic campaigns like this fit into the current and future standards of DTC Marketing that are increasingly moving to engage and educate, facilitate patient conversations with doctors, encourage adherence-- and bring consumers an overall sense of greater hope and control over their own health?

Thoughts? 

 

DTC 21: DTC Marketing in the 21st Century

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With mounting economic pressures and growth of generics, increasing political tension surrounding healthcare and DTC marketing practices, Pharmaceutical and Consumer budgets are under intense scrutiny like never before--forcing new and innovate thinking --starting with how to engage and mobilize high potential consumers to optimize ROI, and ending with focus behind the few efforts that return the most for brands and their customer segments.

Engaging the ever demanding healthcare consumer of the 21st century takes the same insight and hard work as we've always aspired to with traditional DTC efforts and MORE...Consumers today have 21st Century expectations, but little time and patience...

[If you're interested in pharma social media, see previous blogs: "Building on Janet Johnson's 5 Phases of Social Media", "Twitter reaches 9.3 Million Visitors--Pharma Marketers Beware!" and "The Ten Social Media Watch-outs for Pharma and Healthcare Marketers"]

To continue moving from traditional DTC Advertising to DTC in the 21st Century (DTC 21):  consider these six C's where ever possible to more fully engage and learn from your core constituents and consumer segments:

  1. Content that is original, insightful and demonstrates that you know what your consumer segments want.  Provide context to speed uptake. And keep it simple by focusing on what's most meaningful. Interesting and relevant content can take the form of branded or unbranded efforts, educational or interactive, serious or fun eg, healthgaming.

  2. Collaborative Conversation --people prefer two-way diolog--no one likes to be ‘talked at or spoken to"...Find the places where dialog and co-creation can occur within the highly regulated regulatory world of pharma. Work hard to meet the expectations of today's consumer.

  3. Customization to add relevance.  Content that feels more personalized-- ‘for me'-- will consistently get more consideration and action. People love to feel like information, products and services are designed for them, to meet their personal needs and desires--and better yet--if consumers can partake in their own customization. [C.K. Prahalad's book The New Age Of Innovation provides much insight into the possibilities for personalization and co-created value.]

  4. Community grows the feeling of connectedness, and feeling connected is a fundamental attribute of happiness (Link to "Consumer Healthcare Marketing--Pursuing Happiness"blog). Consumers continue to weigh in that peer-to-peer dialog and learning is greatly preferred over manufacturers' speak.  The continued growth of many disease- oriented communities proves this out.

  5. Consumer Confidence is built through authenticity, trust and transparency--often a concern when consumers think about pharmaceutical manufacturers and healthcare providers. The Edelman trust barometer  has continually raised this opportunity.

  6. Consistent Commitment takes time to develop and necessitates consistent actions across touchpoints and customer initiatives.  One-shot and ‘flashy' initiatives may not work to demonstrate commitment.  Nothing takes the place of time to build ever-lasting relationships.

The act of engagement can help consumers feel and act smarter, grab control of their healthcare needs and everyday life, and connect with others, including brands or companies. 

Many in pharma are initiating new marketing and social media efforts (To see the latest go to Dose of Digital's Pharma and Healthcare Social Media Wiki); many are trying new integrated efforts across traditional and new media, and so on...some with more use of the 6 C's --The ones that are sure to build stronger engagement, trust and sales-- and some with less-Those with less may be wise to consider if their marketing endeavors fall below threshold levels of Expected Visitor Experience or EVE... [Originally coined by Jonathan Richman at Dose of Digital blog]. 

How are you engaging your customers? Care to share?

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