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How Pharma Overcomplicates Social Media



I just finished a few days at Digital Pharma this week and it was a great conference. One of the trailblazers in pharma social media, Shwen Gwee, was the chair for the conference and, as an advisor, I got to watch him push for the best of the best content and format. It worked. If you want a great recap of what happened, head off to Twitter and pour through the stream for the conference’s hashtag, #digpharm.

I had seen and heard a lot of what was discussed at this meeting before simply because I get to spend a lot of my time thinking about it. For others that have a different focus in their day-to-day jobs, I’m sure they took away even more than I did. For me, the best part of the conference was the informal, “unconference” discussion that took place for the last two hours of the final day and was lead by Brad Pendergraph from Novartis. There was no stage, no slides, no official speakers, just a bunch of people really interested in digital pharma marketing talking to each other. It’s perhaps not surprising that the conversation almost exclusively focused on social media, as it seems like THE thing to talk about right now (and has for a while). The upcoming FDA hearings on this topic naturally make it more relevant and top of mind (PS: I’ve been invited to speak at the hearing and can’t wait to get in my two cents).

The participants of this final discussion were a good mix of pharma employees and agency/consultant types like me. I mostly listened to the conversation and took a few notes. At some point, I heard one of those simple statements that suddenly helps it all make sense. The “ah-ha” moment.

With constant debate of can we?/can’t we? in pharma companies when it comes to social media, I’ve been saying for a long time that we’re making it too complicated. While there are a lot of objections and concerns within pharma companies when it comes to social media, the one I hear most often and that really bugs me is about the internal regulatory/legal process. There are a lot of other objections that come up, but this one seems to particularly bother me. Here’s what I’m talking about. Let’s say your company starts a corporate blog and (imagine this) allows people to comment. Sure, moderate the comments if you’d like. No problem, just let through the legitimate ones.

Now, here’s where I get frustrated. Let’s say one of the comments is something of a question…something like this: “Great point, but don’t you think that [insert whatever ending you want]?” Clearly, it’s something that the person would like an answer to. They want to engage with you and have a discussion. It’s a great opportunity, right? You know that, so you decide to respond…and that’s when the wheels come off.

Since you’re going to create a response to publish, you have to send it through your review process. It takes a solid two weeks to do that using your normal channels. Or, maybe you’re lucky, you have an expedited process for this type of thing and you can get something out in a couple of days. Of course, by this time, the commenter probably has forgotten all about you. You likely missed a chance to make a major, positive impression. But why? Why did your response have to go through your whole process? “Well,” you say, “you know the answer to that Jonathan. If we post something online, then it has to through our regulatory process. Same rules as if we created a printed piece. What’s wrong with you…have you forgotten everything you learned working at a pharma company?” Okay, so maybe you’d leave out the last part, but you’d say the first part pretty much exactly as I wrote it.

“But, why?” I ask again. I have actually struggled to come up with a simple response to why you could justify NOT putting something like this through your official review process, but hadn’t come up with something yet. As pharma expands its social media efforts, at some point, this becomes a major issue. Are you going to review every tweet, every Facebook status update, and every “Hi, welcome to our forum” comment? You must either really love those regulatory meetings or you really have way too much spare time. Clearly, this isn’t going to be practical. At some point, you have to trust that people will do the right thing and follow the rules without reviewing every single thing they say before they say it.

Crazy…I know. Or is it? As I said, I struggled for a way to simply explain why this isn’t pure madness. It came to me while in the discussion at the conference. My epiphany came courtesy of Brad, who I mentioned earlier. He had the perfect analogy. I’m going to paraphrase just a bit, but here’s the gist:

When someone calls your company’s call center with a question about your product, do your representatives answer the question or do they tell the person that you’ll get back with them in 2-3 weeks?

Not to be outdone, Steve Woodruff, added to this (again paraphrasing):

When your reps are talking to a doctor and the doctor asks a question about your drug, does the rep have to pre-clear a response and get back with the doctor 2-3 weeks later?

Think about both of those statements for a minute. Obviously, we don’t make our call center representatives or sales reps wait for our regulatory process to review their answers before responding to a customer’s question, so why would we have to do this to respond to a customer question on our company blog? Do we trust our sales reps more than the person responsible for our blog? Do call center people get a special set of rules?

I don’t know the answers. I really don’t. You might argue (especially if you’re a lawyer), that the blog response  is “on paper” and therefore, more discoverable while the two analogies are just conversations that aren’t recorded. I suppose it would be harder to “get in trouble” if they aren’t recorded. Of course, this doesn’t put too much faith in your representatives to follow the rules and, the last time I checked, we had these things called voice recorders. If someone really wanted to get you in trouble, they could. Does anyone know the answer to this? I’m not saying that you should let every Tom, Dick, and Harry at your company respond to blog comments, but shouldn’t someone be allowed to do this without having everything approved before they say it?

One final comment that was said around this discussion came from Xavier Petit from Shire. His point related to the fact that we simply can’t ignore that people want to talk to us, so, basically, we have to respond when they come to us. We can’t just ignore them. His analogy was something like this (again, paraphrasing because I can’t write fast enough):

When we realized that people were going to call us on the phone when we gave out our number, did we suddenly decide to cut all the phone lines?

Of course not, but isn’t that what we’re doing when we don’t respond when someone asks us something via a social media channel? We create places for people to comment, but when we realize that they’ll actually do it, we cut off the communication. Actually, it’s exactly the same thing.

So, why are you still here? Shouldn’t you be calling your IT group and telling them to turn off the Internet?

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  • Jonathan,

    Enjoy the post. I agree there must be a solution to the issue of more real time dialogue in situations analagous to your example. The two way conversation that occurs in a user comment is very much similar to conversations that occur in oral speech. Your customer service call is a great example. Why would that conversation between two people be any different at all? A conversation is a conversation. (you and me right here)

    Except that one conversation is different than the other in a substantial way. Oral conversations dissipate into thin air. In most cases, there is no reliable record of the speech, and it is virtually impossible for the speech to be considered labeling or printed or broadcast advertising (the three categories of material FDA/DDMAC regulates). I won't bore you with all of the other details regarding the objective requirements of labeling, advertising, and the postmarketing reporting requirements for these. But, as a practical matter, most of these requirements do not apply mechanically (it is still illegal to "speak" promotionally in a false or misleading or off-label manner).

    Accepting that a two-way conversation by keyboard, telephone, face-to-face or by telephone all accomplish the same EXACT thing, there is the big difference that oral speech is not recorded and then posted for others (to read and forward and retweet etc) who were not part of the original intimate conversation. Because of this, its not so much that the information is printed, as it it that the information is enduring (and can be redistributed at an exponential pace), and FDA could consider the posting and posterity of the comment to be an endorsement of what was said.

    I'm sympathetic though, because I find myself in a rediculous cycle of explaining (at least two or more different reasons why comments pose additional problems). I have to stop myself, because part of me begins to wonder indeed why this should be so complicated. Yes all of the above issues I brought (and others I didn't bring up)up are important, but they relate to a lot of processes and mechanics that although required by FDA regulations, don't really seem to justify the effort and restraint on information. They're just requirements that have endured over time (as a result of regulations written in the 60s), but can't really be addressed unless FDA's regulations change or FDA officially interprets that they don't apply.

    These issues are indeed irrational, but it isn't the company lawyers and regulatory people just making stuff up. They have a duty to ensure that the company complies with the state of the law and the regulations. FDA itself acknowledges that these issues are real by simply calling the public meeting. Hopefully smart people like you can help to create a new model that FDA can accept. Believe me, my regulatory and legal friends throughout industry recognize the many absurdities. But they also have duties, and lets face it, enough inappropriate stuff has occurred over the years that makes everyone (including FDA) approach all of these issues with very cautiously.

    John Murray
  • John, Thanks for weighing in with the other side of the story. Appreciate the detailed comments. Of course, I have an issue any time any company (and this isn't just pharma) where the reason that you do or don't do something in print is because you're more likely to get caught. With spoken word, it's harder to prove, of course. I know it's a little Pollyanna of me, but what if we just said things that weren't illegal? Unfortunately, what's legal and not and the gray areas make this hard sometimes, so I know it's not that simple. Just a principle thing that I know you and everyone else is in agreement with, if only it were that simple.

    As far as your last comment, it's true the regulatory people aren't making this stuff up. I've always tried to say it more like "the FDA won't let you do X" instead of "your regulatory team won't let you do X." I know you're just enforcing the rules in the end, so I don't envy the position you're in. Having said that, many regulatory teams are evaluated (both with performance reviews and incentives) based on whether or not the company receives any actions from DDMAC. Of course, it's really easy to deliver this objective. If you don't approve anything, you'll never get a letter. On the other hand, brand teams are evaluated on product performance and so they have to look for new ways to grow the brand. These two sets of evaluation criteria are in direct opposition to one another. Perhaps this is intentional, but it creates overly conservative people on one end and overly aggressive people on the other. I'd like to see each group share objectives. Imagine if the regulatory people were also graded on product performance and the brand people were also evaluated on compliance with DDMAC policies, etc. What would that look like?
  • Jon,

    Actually, I think we "do" have scripts for many routine things in our lives... and most user questions fall into buckets as the call center folks can surely attest...

    Having said that, I hear what you're saying re: trust.

    One thing about Reps though... Reps aren't talking to patients, they are talking to skilled doctors who are trained to be skeptical, so it is natural they are given more leeway.

    The elephant in the room is, of course, the FDA. They have the power to penalize the pharma companies if they step out of line... but they refuse the clearly draw the line. The hearings in November *may* clear things up... we'll see.

    My point is that there is probably a middle ground that can be pursued that is between the fully open model and the closed Medical/Regulatory/Legal model.
  • Great post, as always.

    You actually unwrap the answer to your question through the post. No, you probably cannot just "trust" someone (anyone) to ad-lib responses to all and sundry blog comments (or Sidewiki for that matter)... however you can have a fairly exhaustive response script just like the call centers. In fact, call centers have branched out into interactive text support, so how is that really different (except that it *should* be considered even more risky than blog comments).

    Great topic!
  • Thanks for the comment, Brad. Imagine instead if we didn't have "scripts" for everything, just like real life. I'd say it's possible for companies not to have scripted, word for word responses, but instead clear guidelines that can help direct what can and can't be said. Some are already doing this because it's simply not possible to create a script for everything. As a sales rep, if I only could answer from a script, I'd be thrown out of every office in seconds. However, we seem to think this is good enough for call centers or social media responses. It's not.
  • Great post Jon. As you probably know us guys over in the UK are tied to strict regulations on communicating directly to the public. There’s a lot of discussion building now about potential changes to our regulations, especially since they are now out of date with the reality of online communication (not least when it comes to Google Sidewiki!) DTC comms will never become a reality in the UK since our attitude towards healthcare is so different to the US. However, it’s always refreshing to see your perspective on facing challenges in the US that are often very similar to those we face in the UK. We even took the liberty to reference your post in our latest blog entry. Keep it coming!

    Angie Wiles

    www.blog.virgohealth.com
  • Thanks for all the comments. Let me address a couple really quickly.

    Wendy, I'm with you on the spoken versus written (and recorded) word. I tried to mention that a bit in my post. I know that's the first thing the lawyers like to bring out, so it's an important obstacle to deal with. Love your statement, "why can’t every pharma – perhaps every brand – identify and train a public-facing, social-media-enabled spokesperson it can trust to engage with customers? They’ve been doing this in PR for years." It pretty much sums up my entire post in a handful of well-chosen words. I guess I never claimed brevity as a strong suit.

    Kay, Great term and way to think about it: "authorized source." We've got "authorized content" now, as you point out, so why not an authorized source? I know some companies have them and don't need everything approved. Marc Monseau (writes @jnjcomm on twitter) doesn't get every tweet approved and nothing bad has happened yet.

    Angie, Thanks for referencing this blog post. I'll be sure to check yours out. To be sure, we have a different set of rules here. Sometimes it makes things easier and sometimes much harder. I know that I would have traded everything I could do DTC for a brand I used to work on for the UK's much more liberal product label. You can't have everything I suppose. I predict they'll be a bit of a loosening of restrictions O-US in the near future regarding DTC. I see it starting as disease state-focused first (which you can somewhat do already) and then potentially moving to branded. I doubt you'll ever see DTC TV, which is great news for you.
  • Kay Wesley
    Totally agree with you Jon, and these issues are over-complicated even more outside the US where pharma cannot be seen to "promote" to consumers. Which is so often interpreted as the inability to answer consumers' legitimate questions in any forum.

    What you highlight is that we need a different set of "rules" for social media versus other, static media - whether printed or on-screen. It might be a good idea to have a notion of an "authorised source" rather than authorised content. For example, companies don't have just anyone answering the phone or visiting doctors, they have people properly trained to do so.

    If we can ensure the people responding in social environments are similarly authorised, then the guidelines must allow some conversational leeway and not effectively expect them to have the whole PI listed in every post (provided it is available).
  • Nice post, Jon, and you make several valid points. I think the crux of your argument is your sentence "At some point, you have to trust that people will do the right thing and follow the rules without reviewing every single thing they say before they say it."

    I've been saying the same ... why can't every pharma - perhaps every brand - identify and train a public-facing, social-media-enabled spokesperson it can trust to engage with customers? They've been doing this in PR for years.

    Of course, from a regulatory review perspective, the difference between call centers, sales reps (and I would add media interviews as well) versus SOCIAL media is the difference between the spoken word and the written word -- which lives forever online. But that still doesn't mean we as an industry can't find a way to have meaningful conversations with those that are willing to engage, and still stay within regulatory compliance.

    Wendy Blackburn
    @wendyblackburn
    ePharma Rx Blog: http://blog.intouchsol.com
    .-= WendyB´s last blog ..14 Signs You've Found the Right Social Media Partner =-.
  • Jon, Thanks for this post - especially since I had to miss the last DigitalPharma session. You give more evidence that a "common law" precedent-based social media policy like J&J's would make it easier for common sense and public/company benefit to prevail in the social media arena. Empowering key staff to speak for the company has worked for decades at call centers and doctor's offices.
  • Keir
    We handled calls from consumers/patients for 2 contraceptive brands. We used to handle appx 400 calls per day when DTC was out there and this fell to maybe 30-50 a day later on. We reviewed call center scripting twice a year, which ran to appx 15 pages and updated them and had them approved thru client med reg (bit exhausting, but critically necessary). Any and all AEs (VERY few and I mean the now famously quoted 1 in 500 is too high) went thru a strict reporting process to the customer. All comments I personally reviewed on a monthly basis (utterly de-identified of course) and re-classified them into 'neater' categories - sometimes finer and sometimes broader and sometimes both. The monthly report out between agency, us and client was fun and provided insights that team used to update scripts, web site, print, re-prioritize information that was more salient TO CUSTOMERS and add more depth where necessary. Creating value for all: - Customers, Brand, Us, Agency, Med Reg. So why not create the same scenario for SM, as you infer? Call center agents aren't and should not be zombies and after learning/repeating the script they add lib to an extent which sounds more natural and creates a real relationship - staying on message of course (I listened in countless times).
  • Keir, Thanks for these real-world stats. This is a killer statement that people need to read: "The monthly report out between agency, us and client was fun and provided insights that team used to update scripts, web site, print, re-prioritize information that was more salient TO CUSTOMERS and add more depth where necessary." Basically, by participating in old-fashioned social media (using a phone), you actually learned stuff about your customers and it made you better marketers who could better deliver what your customers wanted. Makes total sense to me, but somehow isn't quite seen as enough of a value to justify some more "modern" social media efforts. To me, this is a huge reason FOR doing social media work. You learn a ton that can help everyone later on.
  • Pharmas will abandon the excuse of regulatory constraints when they realize that the drugs they sell treat human beings, not "out of order" bodies.
    They need to understand their responsibility in creating value for the health system and the people in it. To do this, they need an internal revolution that among others took out the power of legal-regulatory departments since there is no need to control anything when you are talking/marketing about health, not products.
    .-= Pedro L. Gonzalez´s last blog ..Hable con ell@s =-.
  • Great post, Jon! Thanks for the kind words about Digital Pharma and for the candid take on the last 2hrs of the event (the "town hall", unconference, discussion). Thank also for being a key player in the conference!
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