You’re probably wondering what the image above is all about. Sorry, you’re going to have to read on to get the answer.
Sometimes the biggest inhibitor of the innovation process is ourselves (personal knowledge, expertise, ability, etc.). Sometimes it’s external forces (regulations, guidelines, naysayers). Still other times it’s our interpretation of the external forces. This last one is perhaps the most menacing. Most of us are aware of our own limitations. I’m not about to go out and try to invent a new way to design an airplane wing. I’m not going to try to bring something new to the discussion around a unifying theory of physics. At the same time, most of us know the rules and are forced to live under them. There are these pesky things called laws that always seem to make it all a bit more complicated. Like laws, rules and regulations, such as those from the FDA, often dictate what we can and can’t do. You simply can’t put up a billboard in Times Square proclaiming: “LIPITOR is great for everyone…and whitens your teeth.” Not that you’d do a billboard anyway, but you get the idea. Rules are a good thing in many ways.
However, many times we don’t really know the rules or understand them. Worse still is when we think we know the rules, but really don’t. When this happens, we essentially create a set of “ghost rules” that inhibit our thinking and that of our colleagues. What makes ghost rules especially bad is that they’ve often been around for a long time and no one has ever thought to challenge them. Because these “rules” have often been invented along the way, they are impossible to ever really refute. You can prove that a “ghost” rule is real. Just go look it up. When you see the rule is some FDA guideline, then you’re proved it’s a real rule instead of a “ghost” rule. But how do you prove that a ghost rule isn’t real? If you search for it, you won’t find it anywhere, but because its been around for so long, people might assume that you didn’t look in the right place. It has to be a rule because we’ve assumed it was for so long.
Ghost rules inhibit our thinking and help ensure that we never push to find out what’s possible. You’ve probably been to seminars or had internal training programs about this issue. Maybe you got something out of these sessions and maybe not. For you cynics who didn’t get much out of these sessions, I’m asking for moment that you suspend your skepticism and eye-rolling while I explain why I’m telling you about ghost rules.
Here’s a story that’s been passed around a few times, but the first place I heard it was from David Brennen, the CEO of my former company, AstraZeneca. While I’m not sure his talk was all about ghost rules, his story certainly applied. Here’s the story he told as best as I can remember.
One day a little girl was helping her mother cook Christmas dinner. It was family tradition to prepare the biggest ham they could find along with the many other holiday treats. The little girl watched her mother get the ham ready for the oven and she noticed that just before her mother placed the ham in the oven, she cut the ends off of the ham. The little girl asked her mother why she did that. Did it help the ham cook faster or make it juicier? The mother thought about it for a minute and realized that she didn’t know the answer. The mother’s mother had always done it that way, so she always did it that way. So, to figure out the answer, they called the mother’s mother (i.e., the little girl’s grandmother…stay with me). The little girl asked her grandmother why she cut the ends of the hands. “Simple,” said the grandmother. “When I was growing up, our oven wasn’t big enough to fit the entire ham, so we had to cut off the ends to get it to fit.”
So, do you cut the ends off of the ham and don’t know why? That’s letting ghost rules control the situation. Of course the little girl’s family’s oven could more than accommodate the ham’s size, but they still cut off the ends. It was always done that way, so it continues to be done that way. No one thought to ask why or to understand the purpose. How many rules are you following where this is the case?
Where am I going with this? What’s this got to do with digital marketing in healthcare?
Notice the title of this post again: “What If There Were No Rules in Pharma Marketing?”
I ask you then, “What If There Were No Rules?” There’s no FDA, no DDMAC, no FTC. Your company guidelines and rules don’t exist and your regulatory and legal teams have been disbanded. It’s a free-for-all and there are no rules. The question is: what would you do?
Sounds great, right? But before you answer, keep in mind one very important thing. While there may not be any rules about what you can say, claim about your products, or do in promotion, there’s an unofficial regulatory body that still does exist. People. Patients, doctors, caregivers, researchers, payors, random pharma critics, and commentators/writers (like me). So, you can say whatever you want, but you’re going to be kept in check by all these people. They are the ones who are going to review what you do and decide what’s right and wrong. For those companies that take advantage of this lawless society, the people are going to react negatively. They’ll reject those that make exaggerated claims, those that mislead, and they’ll also reject programs and promotions that just don’t make any sense.
Let’s say you can do anything you want in digital (aka, e-marketing). Would you?
Before you say “yes,” remember a few more things…
- Even in our lawless, hypothetical world, you still have a budget. All the regulatory people are gone, but there are still plenty of finance people. So, whatever you do still has to fit within your budget and you still have to allocate it across channels.
- Just because you make it, it doesn’t mean that people are going to use it. Don’t waste your money to build something no one is going to use.
- People are going to reject and react violently to misleading advertising. Misleading advertising may work in the very short-term, but it’ll kill you over time. Don’t do it just because you now won’t get caught by the Feds.
- Your competition has the same rules (i.e., no rules). Yes, they came along with you to this magical world.
All right, here’s your big chance. No complaints about how regulated the industry is. No fretting about FDA guidelines (or the lack of them). No excuses about how you can’t do anything innovative in digital in the healthcare industry. So, what’ll it be? What are you going to do first? As a little experiment, please answer the poll below to indicate the tactics you might try and their order of priority. If you want to do something that isn’t listed, then write it in. I’ll write a follow up post to share the answers along with some commentary in the next few days. You can choose up three. (Read on after the poll for more commentary.)
Now, since you already answered the poll, let me guess what you chose. Something social media, probably the community on your brand website. Maybe you picked the Facebook or Twitter page. Alternatively, maybe you chose to “enhance” your messages by showing that data that the FDA won’t allow you to promote. Great. Go crazy. Do whatever you want. There are no rules, right?
I tried to warn all of you who went too crazy. Just because there aren’t any official rules, do you think society is going to let you get away with whatever you want? Sure, you can stretch the claims for your product and get out the data from all those clinical trials the FDA won’t let you promote, but are your target physicians going to fall for it or are you going to make matters worse? Sure, you can create an online community on your brand site, but is anyone really going to join? Do they want to be a part of a pharma company’s community or will they just stick with any one of the many out there already? Same thing goes for your Twitter and Facebook accounts. Do I want to be friends with your pharma brand?
Here’s my point with all of this…the FDA isn’t your problem. But you might have two other problems. First, if you and your company cut the ends off the ham as I mentioned in my story, then you might be the problem. Not exactly you, but the way things are done at your company. The second potential problem is everyone else. You might be allowed to do everything in the world, but is it going to work? That is, will it have a positive impact on your brand?
I guess I’m turning this entire debate about the lack of FDA social media guidelines on its head. Sure, you might like a little guidance, but how much differently would you really do things? Even with no rules whatsoever, you still can’t just do anything you want. There are always unofficial “regulators” and picky, smart consumers who know value when they see it and…well…the opposite when they see that.