GSK's U.S. Sales Reps "Europeanized": No Longer Rewarded for Ability to Push Prescriptions

GSK's U.S. Sales Reps "Europeanized": No Longer Rewarded for Ability to Push Prescriptions

According to the Financial Times, "GlaxoSmithKline will this month scrap payments to its US-based commercial staff based on individual sales targets, as it attempts to draw a line under past aggressive marketing practices that have incurred substantial fines" (see here).

GSK’s sales "reps" will no longer receive commissions "based on their ability to push prescriptions. They will instead be paid based on their scientific knowledge, feedback from customers and the performance of their business unit."

An anonymous poster to CafePharma described what the "new" sales model will look like:

You will be judged on 3 categories. Product Knowledge, Customer Value, and Business Acumen. Each one of these will be split into 2 parts. Preparation and implementation. Basically, 6 categories to be subjectively assigned expertise levels by your manager. Hope you have a good relationship... This is how you will get your "cut" of your region's take of bonus dollars.

Oh yeah... you are also no longer referred to as pharmaceutical sales reps... from now on you are called "Customer Facing Staff". No joke...

GSK recently revealed a $3.5bn charge to settle product liability lawsuits and regulatory fines linked to past sales practices (see story here), which may have prompted this change as well as changes in funding physician continuing medical education (CME): GSK will now restrict funding CME courses to a small number of non-profit institutions.

This seems to be a radical shift in the evolution of the pharma sales model that has been followed by companies like Kantar Health. I've written on this subject in several Pharma Marketing News articles over the past year or so. See this recent article: "The Changing Pharma Commercial Model in 2010 and Beyond" (use discount code '95MDK' to download it free).

I also note that in order for a pharma company to reward its sales reps based on prescription volume of physicians they have detailed (the "old" model), the company has to have access to the prescription writing data of individual physicians. It's not a coincidence perhaps that the Supreme Court will soon determine if states have the right to prevent access to that data by pharma companies (see "Supreme Court to Decide Fate of State Laws that Prohibit Use of Rx Records by Pharma"). GSK may be sensing that the decision will go against them and they can take the "high" voluntary road now instead of taking the "low" legally-forced road tomorrow.

Although this model may be new in the U.S., it's not so new in Europe where pharma companies never had access to individual physician prescribing behavior. In Europe -- as I understand it -- pharma companies can only see how prescriptions change among a block of physicians in a certain geographical area more or less equivalent to a zip code in the U.S. Thus, basing sales rep commissions upon "district" performance in the U.S. is similar to how it's done in the EU. From the anonymous post made to CafePharma cited above, it looks like U.S. reps are not going to be happy to be "Europeanized."

Are Doctors Avoiding Twitter Because of "Doctor Bashing"?

Are Doctors Avoiding Twitter Because of "Doctor Bashing"?

"Recently, I was told that some doctors avoid social media because of what they view as 'doctor bashing,'" said Kelly Young (@rawarrior), author of the Rheumatoid Arthritis Warrior site.

In a post to The Orthopedic Posterous blog (here), Young cited a Twitter exchange during a recent #rheum (rheumatology topics) chat. She quoted one doctor who observed this Twitter interaction: "[I'm] a bit uncomfortable with content of these tweets. Doc bashing online puts docs off communicating with patients via this medium."

I am not sure how many doctors use Twitter to communicate with patients. But if they are hesitant to do so, they have many other reasons than online "doctor bashing," which isn't really new. "Doctor bashing" was here already, long ago, on online patient bulletin boards and listservs that are "old school" types of social media.

So what are some of the concerns that doctors have about communicating with patients via today's (Web 2.0) social media tools such as Twitter? How are physicians and patients currently using Social Media? What are expectations and limits? What are Best Practices?

As it so happens, those questions will be addressed at the Doctors 2.0 & You conference in Paris this June (see the agenda here). Denise Silber (@Health20Paris) is the conference organizer. Denise and I have set up an "old school" discussion board on Pharma Marketing Network (here) where you can contribute to the discussion about doctor bashing and other issues that will be covered at the conference. Also, you can follow the #doctors20 hash tag via Twitter (especially if you are a doctor! Don't worry, there will be no "doctor bashing" by us!).

BTW, I am on the advisory board and will be a speaker at the Doctors 2.0 & You conference. My workshop is entitled: "Essential elements of an external corporate media policy." I hope to moderate an interactive discussion looking at "the good, the bad, and the ugly" sides of social media policies as exhibited in the real world and in the end come up with a list of items that must be included in a social media policy that takes into account the different cultural/regulatory environments of the global pharmaceutical market. End of pitch :-)





[Twitter Bird/Medical Caduseus illustration by Bryan Smith.]

P.S. Here's a doctor that should have been "bashed" online, but wasn't. Posted by @nalts on Twitter: "Who knew what the now-arraigned PA abortion doctor did? Umm. The internet? (vitals.com) http://bit.ly/FreezeYourBaby #fdasm"

FDA Needs to Do a Better Job Regulating Food Labels, Says GAO

FDA Needs to Do a Better Job Regulating Food Labels, Says GAO

When it comes to false health claims made by food advertisers, the Federal Trade Commission (FTC) is the federal agency that is empowered to act (see, for example, "Kellogg Engages in Serial Advertising Misbehavior"). But the FDA has jurisdiction over the labelling, which is what is written on the box or container in which the food is delivered.

In a report, the Government Accounting Office (GAO) -- the investigative arm of Congress -- said "FDA Needs to Reassess Its Approach to Protecting Consumers from False or Misleading Claims." In fact, that is the name of the report, which you can find here.

Health claims made by food companies is a "a complex and challenging legal and regulatory" issue. There are several different kinds of health claims that FDA has defined, one of which is a "structure/function" claim. Here's how FDA defines a structure/function claim:

Structure/function claims describe the role of a nutrient or dietary ingredient intended to affect normal structure or function in humans, for example, "calcium builds strong bones." In addition, they may characterize the means by which a nutrient or dietary ingredient acts to maintain such structure or function, for example, "fiber maintains bowel regularity," or "antioxidants maintain cell integrity," or they may describe general well-being from consumption of a nutrient or dietary ingredient. Structure/function claims may also describe a benefit related to a nutrient deficiency disease (like vitamin C and scurvy), as long as the statement also tells how widespread such a disease is in the United States. The manufacturer is responsible for ensuring the accuracy and truthfulness of these claims; they are not pre-approved by FDA but must be truthful and not misleading.

The problem, says GAO, "FDA - unlike the Federal Trade Commission (FTC), which can require companies to submit any relevant evidence as part of an investigation of whether claims are substantiated - does not have the ability to compel companies to turn over their substantiation documents....FDA does not have express legal authority to compel the company to provide such information."

Not only is FDA's legal authority a problem, FDA has not provided guidance to industry on the evidence it needs to support such claims, says the GAO.

It's no wonder that the FTC has had more success quashing these claims than the FDA. One notable example of that is the action taken against Dannon for allegedly overstating the digestive, immunity and other health benefits related to Activia yogurt and DanActive dairy drinks. Dannon had to pay a fine of $21 million and Jamie Lee Curtis can no longer make "deceptive hypes for health and digestive benefits of Activia and DanActive,” Attorney General Richard Blumenthal said. “Dannon outrageously overplayed the health power of yogurt — making unscientific claims about promoting good digestion, preventing flu and enhancing health," said Blumenthal.



Those Activia commercials seemed pretty over-the-top to me and many comedians developed skits around the claims (see this Saturday Night Live excerpt on Hulu). But the typical consumer is confused, says the GAO. "Consumers find it difficult to distinguish among the many different types of claims on food labels, including health claims, qualified health claims, and structure/function claims." I'm pretty confused myself.

The 10 Most Important, Awesome Pharma Marketing Highlights of 2010

The 10 Most Important, Awesome Pharma Marketing Highlights of 2010

The 2010 edition of the Pharma Marketing Yearbook™ is a commemorative record of pharmaceutical marketing issues and highlights of the past year as seen through my eyes and the eyes of my "network" of readers, subscribers, colleagues and followers. It has all been documented here on this blog, which after all is meant to be a log of such things.

I've been told that people like lists, so here's my list of the 10 Most Important, Awesome Pharma Marketing Highlights of 2010. I invite you to suggest your own list in comments to this post. There's space reserved in the Yearbook -- which will be updated periodically -- for your list. I also invite you to "sign" the Yearbook and become part of record.

Awesome Highlight #1: I was quoted in TIME magazine!

Dude! That was awesome for me, but maybe not so much for you.

Awesome Highlight #2: FDA did NOT issue any social media guidance for the drug industry in 2010

Bummer! That's got to be an important event even though it was a NON-event! Some people are giving up on the whole thing and saying "damn the torpedoes, full steam ahead!" Well, maybe not using those words. My Twitter pal Jonathan Richman -- who also loves lists -- says he is "more than a bit tired of hearing about 'the guidelines'" and is "Ready, Willing, and Legal" to proceed with pharma social media "marketing" without guidelines. In fact, he says "not a single industry program on [his wiki] list has ever received a Warning Letter or Notice of Violation from the FDA. Someone is doing something and not getting into any trouble." Novartis's Tasigna branded "Facebook Share" social media widget may not be on Jon's list, BUT Novartis DID get a warning letter from the FDA regarding that piece of marketing (follow the links in this post: "Update on FDA Regulation of Pharma Metadata & Impact on Search"). Come to think of it, THAT letter should have been included as a standalone AWESOME highlight of 2010, but I'm content to leave it as part of #2.

Awesome Highlight #3: The Hawaiian Shirt Off Pharmaguy’s Back!

Congrats! Alex Butler gets the first-ever Pharmaguy Social Media Pioneering Award in recognition of his pioneering efforts. Truly a nice guy! And this proves that I am on the same page as Jon about the possibility of being "legal" without guidelines. However, it takes an extraordinary person like Butler and his team at Janssen to do it without guidelines. Guidelines are for those idiots out there who insist on pushing the envelope and altering the playing field to their advantage. Just imagine a football game without sidelines!

Here's just a bit of Alex's comment he made in the Yearbook:

"Thanks for your work in 2010 John. Obviously a very personal highlight for me was receiving the Pharmaguy pioneer award, especially considering the fantastic list of people I had the honour to rub shoulders with on the nomination list. ... For me though we are in danger of heading down the wrong road. Many companies are trying to do the right thing with the wrong people. ... This is about communication- a fundamental change to the way we communicate about our business and our products, not about platforms. We need people with expertise in communications and in the positive sense, new marketing, to lead the cultural shift necessary within our industry."

For more on that issue -- finding people with the right expertise in new media communications -- listen to this Pharma Marketing Talk podcast: The Coming Digital El Niño: Traditional Interactive Agencies are Facing Extinction.

Awesome Highlight #4: Sanofi-Aventis Meets the Disgruntled Patient

And it wasn't pretty! Yes, it's possible for the pharmaceutical industry to do social media without FDA guidelines, but that doesn't mean that they will do it right. A case in point is the experience that sanofi-aventis had with Shirley Ledlie, who I labeled a "disgruntled patient" because she overwhelmed S-A's Facebook page with images of her bald head. You can read all about this by following the links in the 2010 Pharma Marketing Yearbook, which Shirley signed:

"As I was the 'Disgruntled Patient' feel proud that I managed to closed down the FB page of Sanofi Aventis. Although it reopened it no longer accepts comments from the public. This only goes to prove a point- only SA cant see that! Thank you John for including this episode in your Year Book 2010."

Awesome Highlight #5: The Adventures of Social Media Intern

Speaking of Social Media Faux Pas! Social Media Intern made the scene in 2010. "I enjoy changing the course of social networks, fixing an errant Facebook page faster than a speeding bullet, and jumping over the highest hurdles of any pharma legal/regulatory department," says Social Media Intern. "As an intern I do not make much money. My job is to find pharma social media 'dummies' who launch social media campaigns without thinking!"

Awesome Highlight #6: Dark, Secret, and Fake Patients on the Internet

FDA Guidelines are irrelevant here! In 2010, we learned about "dark" networks that are not open to pharma marketers. You can read all about this by following the links in the 2010 Pharma Marketing Yearbook.

Awesome Highlight #7: I Learned How to “Pronounce Boehringer Ingelheim!

Say it! Funny story... I had to edit the podcast "Scientist Vs salesman: Which approach will enable your sales reps to raise their value to the industry?" to make sure we were saying it correctly! If only I had the rebus to help me -- for more on that, refer to the 2010 Pharma Marketing Yearbook.

Awesome Highlight #8: Digital Pharma Idiot Savants Discovered

Who knew?! A pharma company can be both a feeble-minded digital idiot and a digital genius at the same time!

Awesome Highlight #9: Pharma Payments to Physicians

Whoa boy! 2010 was the year the dirt came out about physicians, medical schools, and advocacy groups who received payments from pharmaceutical companies. So far, disclosures have not been entirely transparent -- more like translucent. Maybe the pharma industry will lobby Congress in 2011 to eliminate the part of the Health Reform law that requires ALL pharma companies to reveal such payments.

Awesome Highlight #10: Pharma Companies Behaving Badly

So what else is new?! 2010 was the year that Johnson & Johnson fell off its much ballyhooed pedestal. I was particularly dismayed that the CEO sent an unprepared underling to face the music before a Congressional Committee! Not a good precedent for women pharma executives when one of their own is hung out to dry like that.

For more details about these Most Important, Awesome Pharma Marketing Highlights of 2010 and more, follow the links in the 2010 Pharma Marketing Yearbook.