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Creating An App-Panic

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iMedicalApps.com published an article detailing Apple’s ‘new’ development policy which will reject any app that includes dosing information for a medicine. Normally I wouldn’t comment on an article from another site in this much depth, but given the way headlines suddenly become ‘insights’ in this business, I thought it would be helpful to clarify a few things.

The article starts with an ominous headline “Apple is now rejecting new medical apps that include drug dosages.” Apple is not doing this across the board. One or two devs got rejected. Which by the way, happens all the time, for all kinds of reasons.  The article goes on from there, “It appears that a number of developers have struggled recently to get medical applications into the App Store.” It doesn’t say how many developers or how wide spread the problem is. And, without any kind of context as to what the app was, or any insight into it’s functionality, it’s impossible to draw any conclusion as to why it was rejected. Given the amount of apps currently in the app store that reference dosing information (mostly by manufacturers) I seriously doubt this is a widespread issue.

A simple reading of the actual rejection sent by Apple illustrates where the developer(s?) went wrong.

“We found that the Seller and/or Artist names associated with your app do not reflect the name of the manufacturer of the medicine referenced in your app or its metadata, as required by the iOS Developer Program License Agreement.

Section 1.2: 

“You” and “Your” means and refers to the person(s) or legal entity (whether the company, organization, educational institution, or governmental agency, instrumentality, or department) using the Apple Software or otherwise exercising rights under this Agreement. For the sake of clarity, You may authorize contractors to develop Applications on Your behalf, but any such Applications must be submitted under Your developer account.

We can only accept medical dosage information submitted by the medicine’s manufacturer.

If you have published these apps on behalf of a client, it would be appropriate for your client to enroll in the iOS Developer Program, then add you to their development team so you can develop an app for them to submit under their developer account.”

I actually see this as a good thing for users. First, the developer in the article clearly didn’t follow the metadata practices of Apple’s guidelines, which is a no-no. Apple has been very consistent on making sure apps are what they say they are and aren’t playing games with metadata to boost rankings. Already I’m suspicious of the developer(s?), since they seem to be unwilling to follow or correct this issue now that Apple has pointed out it’s a problem. Second, if you are publishing dosing information and aren’t doing it on behalf of the manufacturer, you may be publishing the wrong information. Since pharma has so many checks and balances on it’s content, Apple can be assured that anything with a manufacturer’s name on it would have the content verified for accuracy.

As part of gathering the info for the Mobile App Wiki, I spent quite a bit of time in the Android store. Let me tell you, it’s hard to know who’s published what. The requirements are very flimsy for publishing an Android app, and I couldn’t tell if an app was legit or not (see the Bob in IT example).  To be clear, Apple is not asking for the content to be verified, but does have some controls to ensure the veracity of content. Given the importance Apple has placed on medical content and audiences, this seems like a logical restriction to ensure quality for it’s users. So if you are developing an app for a pharma client, or doing it in house, you should be fine.

Is Facebook Robbing Us of Our Political Power?

On March 25th the Human Rights Campaign launched a social campaign to raise awareness for the marriage equality debate currently being deliberated by SCOTUS. You probably saw the campaign, which asked users to change their profile picture to that of a red square with a bold equal sign.  When I checked Facebook Wednesday morning, my entire feed was covered with these logos, as a good portion of my Facebook friends had decided to participate. As I thought about it over my morning coffee, I was struck with the thought that all this activity, while potentially raising awareness inside the walled garden of Facebook, might not actually result in anything of substance. And in fact, it might just be completely meaningless. After all, changing one’s profile picture is a transactional gesture, regardless of the scale. It costs nothing, takes no time, and involves very little risk on the part of the participant.

To which, I posted this: “Changing my profile picture was what really tipped the scales on that political issue” – said nobody ever.”

And then a few minutes later, I pushed the idea even further: “If only Abraham Lincoln had the ability to change his profile picture, perhaps the civil war could have been avoided.

And finally, teasing out the thought to its most ludicrous conclusion, I wrote: “Can everyone on Facebook please change their profile picture to a non-perishable food item? This way we can ensure that the starving children of the world never go hungry again.” (The Huffington Post did a spoof of this 2 years ago which lampooned the issue far better than I could have.)

A good deal of my Facebook peeps were not amused. All in all, those 3 comments generated almost 30 responses. Most of these were enraged for even daring to suggest that this act had no meaning or effect. “It raises awareness!” said one person. “It’s a show of solidarity!” said another. And, in the mother of all ironies, some wrote (on my wall) that I shouldn’t express my opinions (on my wall) about the things they choose to support (on their wall).

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Calm Down. The FDA is Not Trying to Regulate Facebook

Over the past few days, several articles have popped up with the alarming headline that the FDA is now issuing warning letters due to brands use of Facebook’s ‘Like’ function. You can read one of the takes on it here, in Scott Gotleib’s Forbes article “FDA Wants to Regulate Drug Firms on the Internet and It’s Targeting Facebook ‘Likes’.

The problem with this article, and with so many of the others I’ve read, is that the ‘Like’ function wasn’t the reason that the FDA issued the letter. Mr. Gotleib actually describes the issue, but ignores it.

He writes, “In its latest Warning Letter, FDA cited a multitude of serious violations against the marketer of a drug product called Poly-MVA. The company had sold its product through the use of testimonials that were not substantiated by good science, according to FDA. One seemingly blatant abuse, still found on the company’s website when Gaffney checked, was a testimonial from a “Mr. Doug Wray,” whose improper endorsement suggests that by taking Poly-MVA, he was cured of his multiple myeloma. In the Warning Letter, FDA also made a novel mention of the company’s Facebook “Like” of one of these exaggerated testimonials. Until now, it was never clear whether FDA would treat a “Like” (or a re-tweet for that matter) as an endorsement of the underlying content. That question seems to have been answered.”

The problem, from FDA’s perspective, was not the ‘Like’ button. It was the exaggerated claims and unsubstantiated testimonials. The FDA will ALWAYS flag those. Yes, Facebook was the medium some of these claims were issued, but Poly-MVA would have gotten that warning letter if they had pushed these claims in print, radio or whatever.

In pharma, the use of social media is a hot button issue, which brands are mostly terrified of using. I would hope that as industry observers cover issues like this one, they would more accurately describe situation and circumstances, rather than publishing mis-leading headlines that are alarmist and inaccurate.

The FDA isn’t sanctioning Facebook, it’s sanctioning false claims. So all you social media nay-sayers and alarmists out there, please calm down.

EVERYBODY PANIC! Overcoming Cultures of Fear in the Age of the Attention Economy

Prior to joining WPP, I had the experience of working at an agency that was in the midst of trying to change from a traditional mindset to one more focused on digital and emerging technologies. What was fascinating to me was not how resistant our clients were to this change, but how flummoxed the internal culture was by these deviations from the ‘norm’. In ways that I could have never anticipated, I watched people react irrationally and illogically to the pending ‘threat’ of change, oftentimes based on assumptions that were never based in reality.

Pharma has this same issue. It’s terrified of change. I mean mortally terrified. And that presents a problem because, as we all know, change is inevitable. In ways you may not realize, the inherent terror that pervades the industry may be the reason why innovations fail to take root on a consistent basis.

Think about it. All innovations have change as the underlying common denominator. Since most people working in the digital, social or the technology fields are often asked to be agents-of-change, we deal with the results of fear-based risk-assessment all the time. Too often in that process, discussions will drift to analyzing the consequences of sometimes wildly speculative assumptions in order to determine what the worst-case scenario may be. When conversations head down the fear path, they are rarely productive.

So as innovators how do we overcome these sometimes-irrational responses? Are there better ways to evangelize new ideas? Will more data or facts help correct the problem? Hopefully better understanding the causes will better arm us all to more effectively drive change.

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