Pharma is Overcoming Social Media Hurdles - Pharma Marketing News

18 March 2013 Vol. 12, No. 3

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Published by www.pharmamarketingnews.com

Pharma Marketing Network®

Pharma is Overcoming Social Media Hurdles Assessing the Three Biggest Obstacles to Success Author: John Mack

Published by:

Pharma Marketing Network PO Box 760 Newtown, PA 18940 [email protected]

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he pharmaceutical industry has been slow to adopt social media as part of its marketing strategy for a variety of reasons, including FDA regulations regarding fair balance, adverse event reporting, and off-label promotion.

Regulatory Hurdles In April, 2009, for example, several pharmaceutical companies received FDA warning letters that had an impact on how pharma marketers used social media such as Twitter. While the warning letters specifically focused on search ads, the message was clear: FDA is now seriously evaluating compliance with FDA regulations regarding fair balance in communications where space is limited such as in Tweets. Off-label refers to uses of drugs not approved by the FDA for marketing. Doctors are free to prescribe a drug for any purpose, if appropriate. Pharma companies, however, are generally not allowed to mention such uses in promotions or online discussions. They are also wary of off-label discussions by consumers on social media sites they host or own. Recent court cases, however, may open a way for drug companies to engage in such conversations via social media (see, for example, “What's at Stake in the Off-Label Promotion Debate” http://bit.ly/offlabeloped). Adverse event reporting obligations is also a big stumbling block for pharma social media marketers. An adverse event is any health-related unfavorable event (e.g., death) associated with the use of a prescription drug. FDA requires pharma companies to report all adverse events it comes across in communications— including social media communications—it has with patients and healthcare professionals. Many pharma companies fear they will be overwhelmed with adverse event reports from consumers in open comment social media sites such as Twitter and Facebook (see, for example, “Disgruntled Patient Shuts Down sanofi-aventis Facebook Page” http://bit.ly/disgruntpat). Even though studies have shown that this is not a credible concern given the small number of such reports (see slide 25 in “Social Media and the Future of Adverse Event Reporting” http://bit.ly/AERinSM), pharma companies continue to cite the burden of monitoring and reporting adverse events as one of the reasons why they are cautious about using social media. Caution Abounds Pharmaceutical marketers began dipping their toes in social media in October, 2007, when Pfizer launched a collaboration with Sermo, the physician-only online social network, (see “Pfizer has a Gold Mine in Sermo!” http://bit.ly/Pfsermo). The first pharma Facebook page—Janssen's ADHD Moms page—appeared in

June, 2008 (see “The Pharmaguy Social Media Timeline™” http://bit.ly/PGtimeline). When pharmaceutical marketers do delve into social media, they don’t use all the capabilities available. For example, they often “turn off” functions such as commenting and conversations, which make social media most useful for their audience (patients, care-givers, and healthcare professionals). In August, 2011, when Facebook changed its policy and disallowed closedcomment pages, many drug companies shut down their Facebook sites (see “Pharma Facebook Pages Being Phased Out: A Good Run While It Lasted! Did Facebook Kill the Beast?” http://bit.ly/FBclosed). Nevertheless, pharmaceutical marketers have come a long way in integrating social media into their overall marketing strategy. Not every pharma company, however, is at the same point in the adoption curve. Some are more willing to take “risks,” some are more savvy about applicable FDA regulations, and some are more knowledgeable about social media in general. Social Media Obstacle Self Assessment In order to determine how ready pharmaceutical companies are for engaging in social media marketing, Pharma Marketing News began hosting the online “Rate Your Social Media Marketing Readiness” selfassessment tool in December, 2007, when social media first appeared on the pharma radar screen. To date (February, 2013), more than 300 marketing professionals employed by pharmaceutical companies have completed the assessment to determine their personal Social Media Marketing Readiness “Score.” This article summarizes the results and compares results from two different time periods to determine if any progress has been made. Because of the warning letters mentioned above, in 2009 there was a clamor for FDA to host a public hearing to discuss the regulation of pharmaceutical company use of social media to promote Rx drugs (read, for example, “FDA, Tear Down This Wall! A Draft Petition Calling for a Public Hearing”; http://bit.ly/Q7jzA). That hearing was held in November, 2009, and although the FDA has not come out with answers to the questions raised at the hearing, the industry learned a great deal from the discussions, which prompted a surge in social media marketing by the industry. Given the significance of events in 2009, it would be interesting to compare pharma’s social media readiness self assessment results from December, 2007 through June, 2009 (period I) with the period between July, 2009 and February, 2013 (period II).

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Survey Questions and Scoring The questionnaire asks respondents to rate how ready their companies are in overcoming the three most important obstacles to success in social media and assigns points to each: 1. Regulatory Environment – a maximum of 45 points can be awarded 2. Corporate Culture – a maximum of 30 points can be awarded 3. Knowledge & Opinion of Social Media – a maximum of 25 points can be awarded

Corporate Culture • What is your company’s tolerance for risk (e.g., initiating new or untested marketing tactics, launching bold corporate initiatives, etc.)? (10 points, maximum) • How does your company normally react to negative commentary from the media, physicians, politicians and other stakeholders? (10 points, maximum) • How uncomfortable would your company be advertising in a publication or on a web site that often contained editorial content critical of the pharmaceutical industry yet whose readers very closely matched your target audience? (10 points, maximum) Knowledge & Opinion of Social Media

The maximum points reflect the importance of each category. There are several questions within each category that are also rated using a point system:

• Rank your knowledge of social media in general – i.e., how familiar are you with various forms of social media and how they are used? (10 points, maximum)

Regulatory Environment • In your opinion, what is your company’s general regulatory climate? (10 points, maximum) • There are a number of legal and regulatory issues associated with a drug firm’s participation in or sponsorship of social media. How well do you and your colleagues understand these regulatory risks? (20 points, maximum) • How well do you think your company will be able to successfully address these compliance issues? (15 points, maximum)

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• Rank your knowledge of how social media are impacting the pharmaceutical industry’s customers and other stakeholders – i.e., patients, consumers, healthcare professionals, policy makers, etc. (10 points, maximum) • Have you ever personally used social media (i.e., read an online forum or posted a message to an online forum, submitted comments to a blog or written a blog post, edited a wiki, etc.)? (5 points, maximum)

Table 1 displays the average scores. Also see figure 1, page 4. Continues…

Each respondent was given a weighted “score” for each category. This score is expressed as a percentage of the maximum points for that category. The survey collected 313 responses to the Regulatory section questions, 275 responses to the Corporate Culture section questions, and 259 responses to the Knowledge section questions. Is Pharma Ready for Social Media Now? Perhaps. Pharma’s readiness for social media marketing has improved somewhat over the years now that it has had many discussions and more experience with actual social media marketing campaigns. However, there is still room for improvement, especially regarding its “cultural readiness.”

Section Regulatory

Culture

Knowledge

Period

Number of Responses

Score (% of Maximum)

I

164

63.4%

II

149

68.3%

I

151

37.8%

II

124

47.1%

I

141

53.7%

II

118

59.3%

Table 1. Scores for Each Section. Period I: prior to July 2009; Period II: after June 2009 through February 3, 2013.


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Regulatory Obstacles Instead of looking at “scores,” it may be more informative to examine the percentages of all pharma respondents who selected the various answers to the questions. From Figure 2 (below), for example, we learn that 46% of all pharma respondents feel that their companies have a “very cautious” regulatory environment. While the survey asks respondents to be “truthful,” most respondents are marketers who are known to generally feel that their medical/legal review departments are overly cautious.

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Regardless of the sense that their companies are “cautious,” a majority of pharma respondents fee that they have at least some understanding of the regulatory risks associated with social media and feel they can address at least some of the risks. A substantial portion, in fact, feel they can address “all” risks, which seems a bit optimistic given the fact that the FDA has not clarified where it draws the line. Continues…

Figure 1: Pre vs. Post 2009 Scores

Figure 2: Regulatory Environment. All periods, N=313.

Table 2 (below) looks at how these percentages have changed over time. Respondents who took the survey during period II felt that their companies were much more aggressive when it comes to taking regulatory risks and handling FDA warning letters than respondents who took the survey during period I (42% vs. 24%, respectively).

Period

Very Cautious (%)

Neutral (%)

Very Aggressive (%)

I

54%

22%

24%

II

30%

28%

42%

Table 2: General Regulatory Climate, Then and Now.


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The Cultural Hurdle Corporate culture is the second most important factor that determines how “ready” a pharmaceutical company is for social media marketing. Figure 3 shows that a pretty high percentage (39%) of all pharma respondents feel their company has a low to very low tolerance of risk in general, and only 28% feel that their company always responds quickly and constructively to commentary from the media, physicians, politicians and other stakeholders. This is important because social media exposes you and your social media followers to negative comments in ways that were not possible before. Whatever your corporate culture, your company should codify how it will deal with negative comments and other public relations crises that may arise from engaging in social media. In fact, it’s best to have rules of social media engagement to help prevent crises from happening in the first place. An example is Roche's Social Media Guidelines for Employees (see Table 3). Continues… Figure 3: Corporate Culture. All periods, N=275.

7 Rules for PERSONAL online activities Speaking “about” Roche

7 Rules for PROFESSIONAL online activities Speaking “on behalf of Roche”

• Be conscious about mixing your personal and business lives.

• Follow Roche Code of Conduct and Communications Policy

• You are responsible for your actions.

• Follow approval processes for publications and communication

• Follow the Roche Code of Conduct • Mind the global audience • Be careful if talking about Roche. Only share public available information. • Be transparent about your affiliation with • Roche and that opinions raised are your own • Be a “scout” for sentiment swings and critical issues

• Mind Copyrights and give credits to the owners • Use special care if talking about Roche products or financial data. • Identify yourself as a representative of Roche • Monitor your relevant social media channels • Know and follow our Record Management Practices

Table 3: Roche Social Media Principles (Except). Source: http://bit.ly/c9Kacn


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Respondents who took the survey during period II felt that their companies were much more tolerant of taking risks such as initiating new or untested marketing tactics, launching bold corporate initiatives, etc., than respondents who took the survey during period I (56% vs. 25%). See Table 4, below. The Knowledge & Usage Gap Persists The last assessment measure has to do with the respondents’ personal knowledge and use of social media. Looking at the results from all pharma respondents in Figure 4 we see that a majority of pharma employees who have taken this survey have some or a lot of personal experience with social media and realize how it can impact their stakeholders (e.g., patients). Although a higher percentage of period II respondents compared to period I respondents occasionally use social media, the percentage of respondents who frequently use social media themselves has not changed much over the years (see Table 5). In order for a pharma company to overcome the hurdles to using social media, there needs to be “pioneers” within the organization who have the necessary knowledge and personal experience to lead the way. But, as always, pharma is willing and able to hire outside consultants to do the job. Still, without internal knowledge and leadership, things can quickly go astray (see, for example, “Four Useful Lessons Pharma Can Learn from the Pfizer Facebook Hack”; http://bit.ly/paU5oi).

Figure 4: Personal Knowledge. All periods, N=259.

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Period

Low Risk Culture (%)

Neutral (%)

High Risk Culture (%)

I

46%

32%

25%

II

26%

27%

56%

Table 4: General Risk Tolerance, Then and Now.

Period

Frequent User (%)

Occasional User (%)

Infrequent or Non-User (%)

I

38%

39%

23%

II

33%

51%

16%

Table 5: Personal Use of Social Media, Then and Now.


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Pharma Can Overcome the Hurdles Sanofi’s experience with a “disgruntled” patient on Facebook is a good example of how to handle negative criticism (see “Disgruntled Patient Shuts Down sanofiaventis Facebook Page” http://bit.ly/disgruntpat). Afterward, executives from the company made them-selves available to discuss the issues and shared what they learned from the experience (listen to this podcast: “What Sanofi-Aventis Learned from Its FaceBook Experience”; http://bit.ly/bkPq6y). The incident did not stop the Sanofi team from launching other social media initiatives for which they were awarded the 3rd Annual Pharmaguy Social Media Pioneer Award (see http://bit.ly/15nJknH).

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By now most pharmaceutical marketers realize that the FDA—like most government agencies these days—is dragging its feet and “kicking the can down the road” with regard to issuing social media guidelines (see “FDA's ‘Social Media Guidance Cliff’: An Open Letter to Megan Clark Velez”; http://bit.ly/smcliff). They simply cannot wait any longer for Godot. Consequently, many pharmaceutical marketers are dipping more than just their toes in social media and more pharma social media milestones will be achieved in the near future. FDA guidelines will follow the lead of these pioneering marketers. Meanwhile, the “Rate Your Social Media Marketing Readiness” self-assessment tool/survey is still available if you have not already responded. Find it here: http://bit.ly/ahmFll Pharma Marketing News


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