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March 1, 2012
Less than 2 years ago, I got very excited when I saw a Canadian pharma ad on my FaceBook profile. It was the first Canadian pharma ad that I had personally ever seen on FaceBook. You can read my post about it here. We sure have come a long way since then. Throughout 2011 and so far in 2012, I have spotted several ads on my FaceBook profile, by Canadian pharmaceutical companies. In fact, Pfizer Canada might be the first Canadian pharma company to advertise a Schedule F prescription drug name on FaceBook. In Canada, pharmaceutical companies must follow very restrictive Rx-DTC (direct-to-consumer) guidelines. The only things that can be mentioned in the public regarding Schedule F Rx products are product name, price and quantity. The ad below complies with the regulations. GlaxoSmithKline Canada promoted their vaccine Cervarix via FaceBook ads back in Q4 2011. Although the product name and disease state appear in the ad, it complies with Health Canada's Rx-DTC regulations because Cervarix is a schedule D drug, and it is not promoting a schedule A disease. Now Midol might not be a prescription drug, but it belongs to Bayer which is a pharmaceutical company, so I think that they deserve kudos for entering the social media advertisement arena. The Midol FaceBook ads were very consumer-savvy, offering a prize and driving traffic to their site by offering entertainment in the form of punishment on the man in the ad - it doesn't sound very nice, but I saw the site and I did not find it offensive at all. It was all in the name of fun. The rest of the FaceBook ads by Canadian pharma companies that I saw on my profile were all to help raise awareness of certain disease states. As long as no brand name is mentioned, this is a completely acceptable form of promotion according to Health Canada. There might have been ads targeted to men, or younger / older audience, or other demographic that did not fit my profile, so this is by no means a complete inventory of Canadian pharma ads on FaceBook. If you have seen other FaceBook ads by Canadian pharma, let us know in the comments section. If you happen to have a picture, e-mail it to me and I will gladly add it to the post and give you credit for having found it.
August 15, 2011
One of the features that Google Plus offers is the ability to limit and maintain a message within 'circles', which are pre-selected members by the administrator of the Google Plus account. I was very excited about this the day that Google Plus launched, but I had not played with the site long enough to really be sure that it would be possible to contain a message within the circle. Here is a link to my original blog post on the topic. Since that day, I can now confirm that this could indeed work for the pharma industry, even in Canada (and other countries with restrictive regulations). Here are the steps:
- Pharma company sets up a business page (once these are allowed by Google Plus)
- Members who wish to receive messages from the pharmaceutical company must prove somehow that they have a prescription for the product. They can do this by providing the DIN or other information that is acceptable within regulations.
- Only those members with proof of prescription are then added to a pre-defined circle. Be careful not to have too many circles, as it could be easy for an administrator to make an error and send the message to the incorrect circle (and we all know this would result in a regulatory 'no-no')
- Pharma company writes post and clicks on 'share'. Make sure only the appropriate circle is included, and avoid at all cost using the 'public' share button.
- Once the post has been shared, click on the arrow button on the top right corner of the post. This will bring down a drop-menu which allows you to select 'disable comments' and / or 'disable reshare'.
In Canada, pharmaceutical companies must follow very restrictive Rx-DTC (direct-to-consumer) guidelines. The only things that can be mentioned in the public regarding Schedule F Rx products are product name, price and quantity. Not very exciting for consumers, patients, healthcare professionals, or any other stakeholder. However, Canadian pharmaceutical companies are allowed to provide product information to patients who have received a prescription from a healthcare professional for their product. This is referred to as direct-to-patient (DTP) marketing. Unfortunately, it is nearly impossible to develop a gated social site which only includes members who have a prescription for a particular drug, on a mainstream social media site. That is until Google Plus showed up. Of course, there are companies that specialize in customized gated sites, but in this blog post, I am referring to the popular social sites which are already frequented by the general public.
Here is what Ray Chepesiuk, Commissioner (CEO) of PAAB (Pharmaceutical Advertising Advisory Board - Canada), had to say about Google Plus and the pharma industry:
"This is a good example of what I was talking about years ago. The regulations still apply, it is the media that does not fit eg Facebook and Twitter for Canadian Pharma. In Google+ we have an example where the media has changed in a direction that is more amenable to Canadian Pharma communicating through social media to patients and doctors about brand information that is directly related to the product monograph. It will be interesting to see if doctors and patients want to communicate directly within a pharma sponsored site. It does make the creativity box bigger. It will also be useful for internal communications and also with KOLs and other external suppliers. Hopefully pharma will get to understand the utility of these media tools and get good advice on how to adapt them within the regulatory framework. The PAAB can help you do that through the preclearance review program."
Now we just have to wait for Google Plus to allow businesses to set up pages (impatient finger tapping by me and many others).
In the meantime, if you have not tried Google Plus yet, I urge you to do so. Once Google Plus does announce that businesses are allowed on its network, you don't want to be scrambling to start figuring out the network. If it's an invitation that you are waiting for, here is one from me. Just click this Google Plus invitation link and enjoy!
This is a particularly important topic today because FaceBook is no longer supporting pharmaceutical companies who want to disable comments from their FaceBook page walls. You can read more about it here. Some pharmaceutical companies are responding by simply removing their FaceBook pages. You can keep track of which pharmaceutical FaceBook pages are staying up, and which are being removed in the Dose of Digital blog.
Do you think pharma companies who have removed their FaceBook page, or who would like to use a similar type of networking format, would consider Google Plus as an option (of course, only once Google Plus allows business profiles on its network)? Please let me know if the comments below.
April 12, 2011
Here's an interesting Canadian pharma case study where the social media campaign seems to be very well designed and executed, but reaching the intended audience and getting them to take action is proving to be a rather slow process. The details of the campaign are below. Share your thoughts with us on the Maybe Someday campaign in the comments section. In January 2011, Novartis Canada kicked off a social media campaign, "Maybe Someday", designed to raise up to $25,000 for the Canadian MS Society. This is a purely Canadian initiative. Considering their drug Gilenya® (fingolimod) capsules, the first oral disease-modifying therapy developed for relapsing-remitting MS, was approved by Health Canada on March 9th 2011, the Maybe Someday campaign was most likely a pre- and early launch tactic to raise awareness of Novartis as a player in the MS industry, and to develop a relationship with key MS stakeholders. As such, Novartis and Tank, the agency who developed the site, designed the Maybe Someday campaign so that it would be more than just a fundraiser. Despite following restrictive regulatory guidelines, the campaign manages to provide an emotional and memorable experience to the multiple sclerosis (MS) patients, friends, relatives and caregivers that participate. These stakeholders get to write a hope that they have regarding MS, either for themselves or a loved one. What can be more emotional than somebody's hopes and dreams. Just read some of the hopes that were written on the main site so far, and you will see that many people poured their heart and soul into their 'hope' statement. There is no real motivation for repeat visits to the site, but I don't think that was part of the objective for the campaign in the first place. The main component of the campaign is the MaybeSomeday.ca site, where a 2 minute and 15 second video explains the concept of the site and encourages people to write their hope. The main site clearly states that Novartis is behind this initiative. I am assuming that regulatory issues concerning the restrictive Schedule F Rx-DTC advertising in Canada have been taken into consideration, thus restricting all mentions of drugs:
"Please note that we can't post messages about medications and treatments - only inspirational thoughts and wishes."You can scroll through the hopes that people wrote on the left side of the screen, and the bottom left keeps a tally of the English and French hopes which have been written thus far. As mentioned earlier, some of them are very touching. The user's experience would be enhanced if they could comment on the hope of others. But according to the “Social Media Marketing in Pharma: What Works in Canada” conference, a pharmaceutical company is responsible for all content within their site, regardless of who posted it. If people were to share information with each other about their treatments or disease on the Maybe Someday site, Novartis Canada would hold full liability for this content. Novartis could allow it, but they would have to monitor and edit in order to ensure that the comments stay within the guidelines. They could however add a 'like' button or something similar to allow people to at least show support to the author of the hope. Other case studies of Canadian pharma companies who are involved in social media but do not accept comments can be found here, here, and here. I added my hope on the MaybeSomeday.ca website. You can see it just below this paragraph. After your hope has been submitted, you are encouraged to help spread the word about the site via Twitter, FaceBook and e-mail. An automatic message comes up for Twitter, which includes the hashtags #maybesomeday and #MS. Upon scanning the #maybesomeday hashtag: it is being used by many people who are writing a wish on Twitter, very few of which were regarding the MaybeSomeday.ca site (ie. looking for the right girl or guy, wanting to attend a fun event, etc...). FaceBook page as well as a Twitter account. These are promoted from the main site. There is a YouTube channel as well with the Maybe Someday video, but there is no activity at all there and Novartis is not pointing anybody to its direction either. Interestingly, none of these sites mention the name "Novartis", except that the FaceBook page 'likes' the Novartis FaceBook page. However, they all link back to the MaybeSomeday.ca site, which does mention Novartis twice. The FaceBook, Twitter and YouTube profiles were all set up by Tank. The posts are all kind of similar, in that they are promoting the MaybeSomeday.ca site, and are encouraging community members to write a 'hope'. There is little engagement on the FaceBook page because members are only able to 'like' and share a statement. It is noted on the FaceBook information tab that "This page can't save your comments". I decided to test this out. I was able to write a comment, and it was visible for a short little while, but it was then quickly removed. As for the Twitter account, the messages are also very focused on sharing info and the link to the MaybeSomeday.ca site. However, it seems as though Novartis is taking the time to thank the people who are posting information about their site on Twitter. I got a thank you note very quickly after I promoted their site, and I saw a few others on their post timeline. You may have noticed that there is a very small following on both the FaceBook and Twitter profiles. As of April 8 2011 morning, there were almost 1,200 hopes. Novartis has an objective of 25,000 hopes in order to raise $25,000. Considering the site has been up for about 3 months already, that averages out to about 10 hopes per day. At this rate, it will take another 6 1/2 years for Novartis to achieve their objective, which is probably longer than Novartis plans to keep the campaign alive (this is my personal guess, nobody from Novartis told me this). My immediate thought was that perhaps there was a lack of advertising of the campaign. It seems as though there has been FaceBook advertising. People who visit the site and write a hope are then encouraged to help spread the message via their social networks. Traditional promotion of the FaceBook and Twitter sites has been through the MaybeSomeday.ca main site and on the home page of the Novartis Canada site. Based on this info, I do believe that the MaybeSomeday.ca campaign is getting fewer 'hopes' and minimal community members because there is a lack in advertising of the program. Personally, I find the program was designed and implemented very effectively, but low awareness is an issue.
Could the MS Society of Canada help to spread the word about the campaign? I spoke with Rob Petrollini, Manager Web and New Media at the MS Society head office and asked if the MS Society had posted anything about the MaybeSomeday.ca campaign on their social networks. Their Facebook and Twitter profiles have a large number of community members (FaceBook has over 6,400 members, and Twitter has over 2,500 followers as of April 8th 2011). Surely a quick post about the MaybeSomeday.ca fundraising activity would drive their members to help raise the donation and follow the campaign on either FaceBook or Twitter. But unfortunately the MS Society has a policy that prohibits them from promoting any pharmaceutical company program, so they have not posted anything related to the Maybe Someday campaign:"The MS Society's total revenue from pharmaceutical companiesis less than 2% of the amount of money the organization receives annually. Any pharmaceutical funding received by the MS Society of Canada is subject to the MS Society's strict policies that prevent any control or influence by the donor on our decision-making. This is consistent with the ethical principles of Canada's research-based pharmaceutical companies which require that they assure the independence and integrity of stakeholders, in terms of their operations, policies and activities." This is a shame because the Maybe Someday campaign was developed by following the restrictive regulatory guidelines regarding Canadian Rx-DTC advertising. I find it hard to believe that the MS Society community members would have a more negative perception of the society if they were made aware of the Maybe Someday campaign. If a consumer company would sponsor a similar initiative, would the medical organization promote it? I'm not sure what the answer is to that question, but this might be a good topic for a future post. So what are your thoughts on the Maybe Someday campaign? Please share in the comments section. Disclosure: I have no ties with the Maybe Someday campaign, and Novartis is not a client of mine. I just find their site interesting, and I hope that Novartis reaches its goal so that the MS Society of Canada can get the full $25,000.
March 29, 2011
Canadian pharmaceutical professionals who work for Rx&D member organizations follow the Code of Ethical Practices, which, among other guidance, provides guidelines on when and how the organization can provide financial or other type of incentive to physicians. These guidelines help maintain trust in the pharmaceutial industry by consumers and all other healthcare stakeholders, and also provide some consistency in how healthcare professionals (HCP) are treated from one organization to the other.
But how would you feel if all financial and other types of gifts that you provide to physicians for their services were made public for the whole world to see? That's exactly what will be happening in the U.S. in January 2012 (only 9 months away). This is a result of the "Sunshine Provisions" Act, which was passed in March 2010.
Paul Meade of Thought Leader Select (disclaimer: Thought Leader Select is my blog sponsor) has written an article questioning the benefits of the transparency that will be offered by the Sunshine Provisions Act: " Transparency and the Sunshine Provision – Is This a Good or Bad Thing?
Canadian Pharmaceutical Advertisement Advisory Board (PAAB) Commissioner, Ray Chepesiuk, kicks off the discussion with the following comments:
Paul Meade asks "So why are we so concerned with knowing what healthcare professionals get paid for advising healthcare manufacturers?" He goes on to answer his question "Maybe we just want to know that a medical expert is receiving fair compensation for his consultative services in a way that would not bias their judgment. But the transparency that is most important to me when receiving medical care from one of these experts is more about disclosure and conflict of interest, than it is about how much compensation that expert makes for advising manufacturers." That may be a small part of the concern. The large part of the concern from a public health and societal good point of view is "what influence do these key opinion leaders have on the broader population of physicians and the provision of health care services?" This effect may be more profound on public health and on the payers.
Looking at this issue from a broader perspective can help one see why there is a perception that excessive payments from pharma to health professionals may not be a good thing. See the effect of actual cases at Emory and Harvard Universities. The final paragraph states "Disclosure serves a valuable purpose, especially for investigative reporters and attorneys. But the real problem of pharmaceutical industry gifts and payment to doctors is not secrecy, but influence. Doctors who take money or gifts from a pharmaceutical company are more likely to prescribe that company's drugs, write favorable journal articles about the drugs, give lectures recommending the drugs and suggest adding the drugs to a hospital formulary. That influence does not disappear when the payments are disclosed. To fix that problem, the payments must be eliminated."
For those who are less familiar with the Canadian Rx&D Ethics guidelines, here are a few excerpts that highlight how Canadian pharma can and cannot compensate healthcare professionals. For the full code of ethical guidelines, go here.
- 6.1.3 Members must never provide a donation, directly or indirectly, in order to have access to a health care professional.
- 6.2 Access Fees: Under no circumstances shall a Member company pay a “clinic room rental fee”, “clean-up fee” or any other similar type “fee” that can reasonably be construed as a direct or indirect payment in order to gain access to a HCP.
- Advisory boards: 13.3 Remuneration must be in the form of an honorarium (fair and reasonable). Travel, accommodation and out-of-pocket expenses in providing the consulting service, where warranted, may be reimbursed.
- CHE: 4A.3.4 Member companies should not be involved in the development of, or payment for social functions conducted in conjunction with any CHE event.
- 4A.3.5 Grants and honoraria may be provided to health care professionals who speak at or moderate CHE programs. Such grants and/or honoraria do not apply to other health careprofessionals attending the program. Members may provide financial support for a maximum of ten (10) individuals to any one international CHE event. Notwithstanding the provisions in Section 7B.1.3. a member company may extend hospitality to all their duly sponsored health care professionals to international CHE event. For hospitality, please refer to sections 7B.1.4 and section 7B.1.5.
November 12, 2010
Several months ago, the PAAB (Pharmaceutical Advertising Advisory Board) held 3 social media marketing sessions called “Social Media Marketing in Pharma: What Works in Canada”, twice in Toronto and once in Montreal, where they provided some of their insights on Canadian regulations regarding pharmaceutical social media marketing. This meeting even had a representative from Health Canada as a panel member. Then earlier this month, they presented even more guidance at the Eye For Pharma eMarketing Canada conference. Just yesterday, they made their slides from the conference available on the PAAB website: PAAB Guidance on Social Media Marketing (61 slides). Enable audio on your computer as each slide has audio. The audio track on each slide is by Patrick Massad (Chief Review Officer at the PAAB). Beware - the file is huge. It slowed my computer down for several minutes. But once you go through the slides and audio, you will find that it is full of valuable information, some of which was not presented at the recent eMarketing conference due to lack of time. The PAAB has also made itself more available to the Canadian pharma community by setting up a LinkedIn, FaceBook and Twitter profile. The PAAB has been using these avenues to not only update the industry on PAAB activities, but also to share information about social media from other countries. On Twitter, the PAAB even posted a request for people to join one of their social networs and to start a discussion. As far as I know, the level of outreach by the PAAB to the pharma industry with regards to guidance on the regulations that impact social media marketing is the first of its kind worldwide. Please correct me if this is inaccurate. I am aware of the FDA meetings held a while back, but so far, no guidance has been made available since those meetings. Whether we like the regulations or not, and whether we feel the regulations are doing justice to the mantra of social media being open for engagement by all stakeholders, we have to give credit to the PAAB for their efforts in helping the Canadian pharma industry understand what we can and cannot do within the legal framework. I am not a fan of the current Rx DTC regulations in Canada. They are outdated, and I would like to see these regulations re-visited and modified. But I don't blame the PAAB for those regulations. They did not make the rules. They just help us work within them. The only recommendation that I would have for the PAAB (and Rx&D as well for that matter), is to include something about social media guidelines as part of their overall set of guidelines. Perhaps that is in the works and I am just not aware. Do you think the PAAB is doing a good job in educating the Canadian pharmaceutical industry on how to apply current regulations to social media campaigns? Do you have any suggestions for them to improve their outreach to the industry? Disclaimer: I have been involved with the PAAB on various social media activities, but this post is my personal opinion. The PAAB has not had any input or influence in the content of this article. Stay in touch, Natalie Connect with me on the following networks: FaceBook, Twitter, LinkedIn