Pfizer's Social Media Initiatives are Getting Old

Pfizer's Social Media Initiatives are Getting Old

On June 18, 2012, Pfizer launched "Get Old," a multi-year initiative supported by nearly a dozen advocacy organizations. Why? According to Pfizer, it is part of Pfizer’s mission to improve the health and well-being of people at every stage of life," not to mention that Pfizer -- like many other drug companies -- is actively working on drugs to treat Alzheimer's Disease. That goal may indeed be a multi-year endeavor. Institutional investors doubt that treatments for Alzheimer's disease being developed by Pfizer (and Lilly) will "achieve the main goals of their ongoing late-stage trials" (see "Survey shows dim faith in Lilly, Pfizer Alzheimer's drugs").

Clinical research doubts aside, Pfizer is obviously courting advocacy groups, which include Alzheimer’s Association, Easter Seals, International Longevity Center at Columbia University’s Mailman School of Public Health, Men’s Health Network, National Alliance for Caregiving, National Black Nurses Association, National Coalition for Cancer Survivorship, National Consumers League, National Family Caregivers Association, Patient Advocate Foundation, Society for Women’s Health Research, Visiting Nurse Associations of America, and WomenHeart: The National Coalition for Women with Heart Disease. This kind of advocacy activity typically is part of prelaunch "marketing" campaigns.

At the center of the "Get Old" initiative is a "first-of-its-kind online community," GetOld.com, where people can "get and share information, add to the dialogue and contribute to the growing body of knowledge about this important topic," according to the Pfizer press release (here).

Of course, being near the age of the target demographic for Alzheimer's Disease, I decided to check out the web site. Here's what the site looks like today (click on image for an enlarged view):

The site allows registered visitors -- including me -- to "Share your thoughts and experiences about getting old." You can post links, videos, photos, or stories (including comments up to 1000 characters) to the site. You can even submit comments to other posts and "Like," tweet, or email comments. Every comment submitted appears to be reviewed before being uploaded - a process that Pfizer says should be completed within 48 hours.

As usual, I tested the system - specifically the ability to upload a photo and submit comments. I decided to upload an old photo of myself when I was 22-25 years old and add some nice comment about what I may have been thinking at that age about growing old. When you "share thoughts" (i.e., create a "sticky") you can check off how you currently feel about getting old: Optimistic (blue), Angry (red), Prepared (green), or Uneasy (orange). The posting boxes for Prepared and Uneasy are shown in the graphic below (click to enlarge to actual size):

My comment, for the record was: "This is me at about 22-25 years old. At the time, I did not worry about getting old because I was more worried I'd get killed in combat in Vietnam. Today, some young people have similar worries, but added to that, are worries about finding a job - even when they do come home from combat!"

Even if you do click on the above images to get full-sized views, you might have trouble reading what's on the screen. This can be best illustrated in the "Thank You" box displayed after creating a "sticky":

The above screen shot is ACTUAL SIZE. I don't know about you, but I found this IMPOSSIBLE to read because the contrast is TOO LOW! I feel "Angry" about this and I am sure most people older and younger than I feel the same. Did Pfizer test this site with real people before launching? I seriously doubt it. If they did, they probably didn't take the advice of their focus groups, but took the word of the interactive agency that created the site that it was "cool" with nice subtle colors!

UPDATE (20 Jul 2012): Yesterday, Pfizer announced at a conference in NYC that it relaunched the site with a number of improvements, including increasing the font size (somewhat). Pfizer also made some improvements in the contrast area, "where we had some challenges," said Robert Libbey (@bob_libbey), Snr Dir, Global Colleague Communications, Pfizer. "We're working on more improvements to draw more users in a user-friendly way," said Libbey. The new "Thank You" screen shown below illustrates the improvements in readability:

Most of the "sticky" boxes currently on the site are blue or green ("Optimistic" or "Prepared," respectively). That's because they are mostly sticky stuff posted by Pfizer -- including "Editorial Desk," "Pfizer Colleague," or one of the Pfizer partners mentioned above.

I did find a few posts that appear to come from ordinary people like "Desi1612," supposedly a "prepared" 63-year old male. He said: "I am truly loving growing up, some say "finally". I appreciate all I have done more and all I have much more. I do not worry about the future, what is - is, so bring it on and I will find a way to embrace and enjoy it" to which I responded with my own comment: "Thanks for sharing your thoughts."

NOTE: The site also includes YouTube videos posted by Pfizer such as the one titled "I'm Older Than You" (find it here). It's interesting that I can post comments to this video on the Pfizer "Get Old" site -- where Pfizer can pre-moderate and block comments before they are uploaded -- whereas I cannot post comments to the same video on Pfizer's YouTube page where "Comments are disabled for this video." Why would Pfizer allow comments on one "channel" and not the other? It is, I believe, possible to enable comment moderation for YouTube videos (see here, for example). Could it be that Pfizer does not have the FTEs to handle many comments likely to come through YouTube vs. the trickle of comments that come through its own Website?

Speaking of the colors to represent how people feel... I suppose this site is meant ONLY for U.S. audiences because colors are very culturally charged. Red, for example, may be an appropriate color to represent "Angry" for U.S. audiences, but for Asian people it means "happy happy happy!' (hence, traditionally Asian women wear red wedding dresses). I've been told that there currently are more Chinese Internet users than U.S. users. Maybe Pfizer has different "Get Old" sites for different countries such as China or maybe the site is banned in China altogether!

There are components of Pfizr's initiative other than the web site. Research Pfizer commissioned as part of the Get Old initiative asked more than 1,000 Americans (I guess it IS all abou US after all!), who are 18 to 65+ years old, about how they feel about getting old. See this infographic for a summary of some results of that survey.

UPDATE (1 July 2011): My post was accepted. In a field of greens and blues, my orange ("Uneasy") sticky stands out!

UPDATE (6 July 2011): When looking for my post today, I couldn't find it. I posted a notice to Pfizer's GetOld FB page (here) and also Tweeted about it to @pfizer_news, who suggested I contact them by email at GetOldInfo@pfizer.com. Within a couple of hours, I got a response:

Hi John:
Thank you for contacting us! While we do not delete posts, the content presented in the “jumble view” is determined by date-submitted – so as time goes by any given post is less likely to appear as new submissions are being received daily. We have provided the steps for viewing your sticky below. We appreciate your patience and apologize for any inconvenience.
Please let us know if we can be of further assistance.
Kind regards,
The Get Old web team

I followed the instructions and was able to find my post. Essentially, you have to log in, select your age and gender, and then enter your screen name in the search box. I guess I got my 15 minutes of fame. Who can ask for more than that? I apologize for wasting Pfizer's time on such trivia, but it's good to know that there is someone behind the scenes helping.

Pharma Engages Patients in Real World, Not via Social Media

Pharma Engages Patients in Real World, Not via Social Media

Some pharma pundits -- mostly consultants who want more pharma clients -- see great potential for pharma to use social media such as Twitter and Facebook to "engage" consumers and patients.

Yet, pharma is lagging behind other industries in its use of social media for engaging customers (see chart below). That's one takeaway of a benchmarking survey conducted by IBM in early 2011. The survey polled eight hundred sales and marketing managers (including 88 from pharma companies) who, provided information about their organizations' key practices and performance indicators. You can find the full survey report here.

Why is this?

Most people will claim that FDA regulations and lack of guidance are the main culprits. Keep in mind, however, that FDA regulates only branded communications between pharma and consumers or physicians. There are plenty of ways that pharma can use social media to engage without mentioning brands. See, for example, "Supporting Patients via Twitter and Beyond" in this month's Pharma Marketing News (subscription required).

So why isn't pharma doing more t o"engage" consumers via non-branded social media?

I think it's because pharma has a long tradition of engaging their clients (patients and physicians) the old-fashioned way - in person. Obviously, pharma sales reps have always engaged physicians through personal contact. It's only recently that this kind of activity has been scaled back.  Some of the pundits I refer to above would say that's because of the ascendancy of "non-personal" (ie, digital) promtion (see, for example, "Building the 'New' Pharma Physician Marketing Model" (pdf; no subscription required).

But a lot of the scaling back of sales reps in the field is due to the fact that there were TOO MANY sales reps calling on the same doctors promoting the same products. Many physicians have grown weary of that practice (sales "pods") and put limits on when sales reps can see them (see "Are Sales Reps Necessary?").

What about consumer/patient engagement?

Pharma also has a long tradition of engaging patients in the REAL world such as through support of patient advocacy groups and disease awareness campaigns. Pharma uses Twitter to promote these activities. An example is this one from @GSKUS: "Nearly 100 #GSKvolunteers embark on life changing assignments to*build healthy communities all over the world.**http://t.co/FloiUmmi*"

So, social media is often used by pharma to promote its real-world engagement with patients and consumers. But social media is used for promotion -- one-way communication  -- not for two-way engagement.

Personally, I think this is a good use of social media by pharma. But it's not going to bring a lot of business to consultants who want to do more engagement exclusively via social media (i.e., "non-personal engagement").

Drug Ads & Coupons: Who's the Decider? The Patient, the Physician, or the FDA?

Drug Ads & Coupons: Who's the Decider? The Patient, the Physician, or the FDA?

The FDA is concerned that the use of sales promotions such as free trial offers, discounts, money-back guarantees, and rebates in direct-to-consumer (DTC) prescription drug ads "artificially enhance consumers' perceptions of the product's quality" while also resulting in an "unbalanced or misleading impression of the product's safety." To test whether or not this is true, the FDA will soon start yet another study focused on Rx print ads: "Effect of Promotional Offers in Direct-to-Consumer Prescription Drug Print Advertisements on Consumer Product Perceptions" (see Federal Register Notice archived here).

[I recently posted about another planned FDA study to determine if disease awareness information in branded ads confuses consumers. See FDA Concerned About Product (eg, Lyrica) Ads That are Too "Educational"]

The history of this study is long and mysterious. I first blogged about it 2006; read "FDA, Coupons, and Sleep Aid DTC Ads." Shortly after that the Federal Register notice regarding the study was "yanked" (see "FDA Backs Down on Coupon Study"). Also, the Advertising Age and Wall Street Journal articles cited in those posts can no longer be found in the archives.

In September, 2011, however, the proposed study re-emerged in the Federal Register (here). Whatever happened between 2006 and 2011 is anybody's guess, but I assume that the Bush era FDA leaders axed the proposed study when they learned of it. By September, 2011, these people were on the way out and the door was open again to propose the study anew.

Anyhoo, I want to focus here on comments that PhRMA made in response to the proposal. Alexander Gaffney (@AlecGaffney), Health wonk and writer of news for @RAPSorg, summarized the general attitude of PhRMA (see "US Regulators Move Ahead With Planned Study on DTC Marketing"):

In its statement to FDA, PhRMA wrote it was “concerned that the study, as currently envisioned, will not yield information that is relevant to FDA’s regulatory responsibilities to ensure that DTC advertising is truthful, accurate and balanced.”

“Although the study may provide interesting information about the effect of promotional offers on consumer attitudes toward a brand,” explained PhRMA, “it likely will provide little information on whether promotional offers create or contribute to false or misleading advertising, particularly under real-world circumstances or whether additional regulatory requirements are warranted.”

PhRMA: The Physician is the Decider
I dug a little deeper into PhRMA comments (here) and was surprised to learn that PhRMA's position is that "it is the physician, not the patient (my emphasis), who ultimately must decide whether the benefits of the advertised drug outweigh its risks for any particular patient." Thus, says PhRMA, "the risks of 'misperceptions' ... should be even lower [PhRMA's emphasis] for prescription drugs than for experience goods [i.e., a product or service where product characteristics, such as quality or price are difficult to observe in advance, but these characteristics can be ascertained upon consumption] because any potential misperception, of necessity, will be quickly corrected prior to use through consultation with the patient's treating physician."

This is a very paternalistic POV in this day and age of social media and patient empowerment. Actually, it is the old "learned intermediary" defense that the drug industry often raises (in the past, less so these days) to shield itself from blame when things go wrong.

FDA must respond to comments submitted, but I couldn't find a direct response to PhRMA's comments cited above. I did find, however, the following comments and FDA's response that addressed the issue of the patient-physician relationship generally:

(Comment 22) Two comments mentioned that the study does not assess how consumer perceptions of product risks and benefits are translated into a discussion with their health care provider. One comment stated that because these products can only be purchased after a discussion with a health care provider, the study be redesigned so that consumer perceptions are measured after a discussion with a health care provider.

(Response) We concur that this study does not address behaviors, such as how ad perceptions are translated into a discussion with a health care provider. As noted previously, one purpose of DTC advertising is to motivate consumers to engage in a discussion with their health care provider about health concerns. Another purpose, supported by research findings (Refs. 20 and 21), is to increase awareness of available treatments. DTC advertising does not exist solely in the confines of a doctor's office; rather, DTC advertising targets consumers outside of a doctor's office, with the goal of prompting consumers to ask their physicians about the product. In deciding whether or not to discuss a particular product with their health care provider, consumers presumably are engaging in some sort of judgment about the product being promoted. Therefore, clear communication of risks and benefits is needed for consumers before a consultation with a physician, and it is valid to measure these impressions.

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Bogus Predictions of Pharma Industry Online Ad Spending

Bogus Predictions of Pharma Industry Online Ad Spending

Here's a headline, versions of which I have been seeing for years: "Pharmaceutical Advertising Spending Shifts to Digital." That's how Business 2 Community -- "an independent online community focused on sharing the latest news surrounding Social Media, Marketing, Branding, Public Relations & much more" -- describes the latest data from eMarketer, which predicts that "pharmaceutical" online marketing will increase by a staggering 23.3% in 2012 vs. 2011 (see here and chart below).

First, eMarketer's data are not specifically focused on the pharmaceutical industry. The data includes ALL healthcare industries, including doctors, hospitals and "other entities that deliver health services such as health maintenance organizations (HMOs)" and, I presume, health insurance companies. What percent of the $1.58 billion in online spending predicted for 2012 is pharma specific? Probably over 50%, but not 100%. Perhaps 75%? Your guess is as good as mine (or eMarketer's).

So the headline above is misleading. It should read "Healthcare Advertising Shifts to Digital." But is it really?

Another problem is that eMarketer's predictions about online healthcare ad spending have been "all over the map" by which I mean wildly inaccurate and meaningless. In 2007, for example, eMarketer predicted that the spending on online HC marketing would be $2.20 billion in 2011 (see here and chart below). But the eMarketer chart above now indicates the number is closer to $1.28 billion, which is quite a difference.

So, why should we believe eMarketer's prediction that online HC ad spending will increase by 23.3% this year? You tell me.

Boehringer Ingelheim Shows How to Support Patients via Twitter and Beyond

Boehringer Ingelheim Shows How to Support Patients via Twitter and Beyond

One of the uses for pharma Twitter accounts that many ePatient advocates recommend is to directly support patients seeking help regarding their Rx products (see, for example, this Pharma Marketing News (PMN) article: "Use of Twitter for Patient Support" [free pdf]).

Although nearly two-thirds of respondents to a PMN survey thought that using Twitter for patient support activities would be somewhat or very effective, relatively few pharmaceutical companies are doing this on a regular basis. From time to time, however, I do see it happening.

Today, for example, I discovered that Boehringer Ingelheim tweeters in Germany (@boehringer) responded to a tweet from a U.S. caregiver who was seeking help in purchasing Spiriva HandiHaler for her mother. First, this person complained to @BarackObama because of the high cost of the product:

@BarackObama @Messina2012 cam some1 tell me y my moms ESSENTIAL medication is $135.00 a month? That's 2 MUCH 4 some1 on a fixed income :-(

She then followed up with a tweet sent to the attention of @Boehringer:

@Boehringer hellol My mother needs 2 purchase Spiriva HandiHaler & her insurance wont cover it. Are there any coupons or assistance 4 this?

Although @Boehringer is the German-based Twitter account of BI, it did respond. Here's the conversation:

I commend BI for using Twitter to carry on a conversation about a product rather than just providing @Shaundre an 800 number to call. Also, BI -- in Germany -- has taken the extra step in contacting the US office on @Shaundre's behalf. Good job, BI!

Note that BI first asks if @Shaundre spoke to her (or her mother's) doctor about the issue. Preserving the patient-doctor relationship is important when pharma deals directly with patients or caregivers. About 57% of respondents to the survey mentioned above were of the opinion that use of Twitter by pharma for direct-to-patient support activities could be viewed by physicians as coming between them and their patients. Only 30% said these activities would not interfere with the patient-physician relationship.

UPDATE: @boehringerus, BI's U.S. Twitter account, posted this tweet:

@Shaundrie: Thank you for your message. Send your contact info to usnews@boehringer-ingelheim.com and we will contact you directly.

FDA Concerned About Product (eg, Lyrica) Ads That are Too "Educational"

FDA Concerned About Product (eg, Lyrica) Ads That are Too "Educational"

In a recent Federal Register notice (find it here), FDA outlined a study it plans to do to determine if disease awareness information in branded ads confuses consumers; i.e., if consumers confuse educational information about a disease with specific product claims approved by the FDA. As usual, FDA will only study print ads -- not Internet-based ads.

"Sponsors [pharmaceutical companies] may choose to include disease information in their full product promotions," says FDA. "Such information is designed to educate the patient about his or her disease condition. However, in some cases a full description of the medical condition may include information about specific health outcomes that are not part of a drug’s approved indication... When broad disease information accompanies or is included in an ad for a specific drug," says the FDA, "consumers may mistakenly assume that the drug will address all of the potential consequences of the condition mentioned in the ad by making inferences that go beyond what is explicitly stated in an advertisement."

FDA cites as an example a hypothetical ad that mentions "diabetic retinopathy," which is damage to the eye's retina that occurs with long-term diabetes. "...the mention of diabetic retinopathy in an advertisement for a drug that lowers blood glucose may lead consumers to infer that the drug will prevent diabetic retinopathy, even if no direct claim is made. The advertisement may imply broader indications for the promoted drug than are warranted, leading consumers to infer effectiveness of the drug beyond the indication for which it was approved."

I couldn't find a diabetes-related print drug ad that mentioned "diabetic retinopathy," but I did find one in today's Parade magazine that informed me that "Diabetes Damages Nerves." That ad (shown below) promotes Pfizer's drug Lyrica, which is indicated for the treatment of "Diabetic Nerve Pain." It is NOT indicated to prevent nerve damage caused by diabetes.

What I see when quickly glancing at this ad is "DIABETES DAMAGES NERVES" (all caps), then "PAIN," (also all caps) and, finally, "LYRICA" (also all caps). If I were a typical consumer with diabetes, I might think that LYRICA prevents damage to my nerves, which would be an incorrect assumption.

BTW, the ad also says "Lyrica is believed to work on these damaged nerves." What does that mean? Does Lyrica work on repairing the nerves? or does it work on shutting down the nerves so you don't feel pain? And, what does "believed" mean? It's all very mysterious!

This ad probably is not the best example of an ad that FDA has in mind -- it was just the best example I could find at the moment. I'll have to buy a few more consumer magazines to find other, more relevant examples. If you know of one, please point it out to me.

Here Come the Pharma Wikipedians!

Here Come the Pharma Wikipedians!

Should pharmaceutical companies appoint employees as Wikipedia "spokespeople" to perform all edits to Wikipedia articles on behalf of the company? That is the opinion of Bertalan Meskó, MD, founder and managing director of Webicina.com, who invited pharmaceutical companies to "employ a Wikipedia editor if you want to make sure only evidence-based information is included in entries about your own products" (find his letter here).

Recall that PhRMA -- in comments submitted to the FDA (see "Accountability for Pharma Content on Social Media Sites") -- suggested that manufacturers would welcome correcting misinformation about their products posted to sites like Wikipedia if these corrections were not subject to FDA regulation.

"FDA," said PhRMA, "should confirm formally that, while it is not possible for manufacturers to monitor or correct all inaccurate information about their products on the Internet, such corrections by manufacturers in response to inaccurate postings will not be considered promotional labeling. FDA's adoption of such a policy would thereby allow manufacturers to correct inaccurate information about their medicines on the Internet or social media (e.g., Wikipedia, Sidewiki, blogs, or other websites) if they should become aware of such information."

PODCAST
Pharma does not have a stellar record when it comes to editing Wikipedia articles. See, for example, "Simply Irresistible: Abbott Tampering with Wikipedia Entries" and "Web 2.0 Pharma Marketing Tricks for Dummies." So it's no surprise that this raises a number of interesting issues that were hotly debated during a recent #hcsmeu Twitter chat. That discussion will be continued in a Pharma Marketing Talk podcast on Tuesday, July 17, 2012. You are invited to listen or call in with your opinions. For more information, go here.

SURVEY
Meanwhile, I invite you to respond to the short survey below, which asks your opinion regarding the issues. Specifically, the survey asks whether or not you agree to the following statements:

• Pharma should NOT correct Wikipedia "misinformation" under any circumstances.
• Pharma should appoint employees or hire outside "Wikipedians" (ie, trained specialists) to edit "misinformation" on Wikipedia.
• When pharmaceutical company employees or agents correct "misinformation" on Wikipedia, they must reveal their ties to the company.
• When pharma corrects Wikipedia "misinformation" about Rx products, FDA should NOT consider this promotional labeling subject to regulation.
• If pharma edits Rx information on Wikipedia and this information is later re-edited by others, pharma should not be held responsible for any resulting misinformation.

Create your free online surveys with SurveyMonkey, the world's leading questionnaire tool.

Abbott's Anti-Biosimilar Stance is Anti-Consumer

Abbott's Anti-Biosimilar Stance is Anti-Consumer

The pharmaceutical industry often wonders why it has such a bad reputation with consumers -- nearly as bad as the tobacco industry -- considering it saves lives, as opposed to the tobacco industry, which ends lives. Well, to understand why this is so, you need look no further than actions such as Abbott's April 2, 2012 citizen's petition against FDA approval of biosimilars (read more about that and find a copy of the petition here: "Abbott Labs Petitions FDA to Disallow Biosimilars").

According to the FDA (here):

The Patient Protection and Affordable Care Act (Affordable Care Act), signed into law by President Obama on March 23, 2010, amends the Public Health Service Act (PHS Act) to create an abbreviated licensure pathway for biological products that are demonstrated to be “biosimilar” to or “interchangeable” with an FDA-licensed biological product. This pathway is provided in the part of the law known as the Biologics Price Competition and Innovation Act (BPCI Act). Under the BPCI Act, a biological product may be demonstrated to be “biosimilar” if data show that, among other things, the product is “highly similar” to an already-approved biological product.

The law protects the original biologic drug from copies for 12 years after approval.

"If the challenge succeeds," says WSJ, "less-expensive versions of complex biologic drugs couldn't go on sale in the U.S. for years, and consumers may never have access to facsimiles of existing treatments such as Abbott's rheumatoid arthritis therapy Humira, which had $3.4 billion in U.S. sales last year and is projected to be the world's No. 1-selling drug this year."

Abbott "contends that its drug isn't copyable under the law, because regulators would need its Humira trade secrets to approve a biosimilar and would thereby violate its constitutional rights. The company said it is protecting an investment of 'massive amounts of capital' and the 'great risk' it took developing the drug. In fact, Abbott contends that no biologic approved before the law was signed should be considered copyable."

"Critics of Abbott's position say that the argument lacks merit and is anticompetitive, and that trade secrets aren't necessary to prove that a copy will work like the original. The critics also contend Abbott is backtracking on its support for the legislation and ignoring the potential impact on the country's spiraling health-care spending."

Considering that Abbott Labs will soon have the NUMBER 1 selling drug in the world (see below) -- taking the crown from Pfizer's LIPITOR -- it makes perfect sense that Abbott should act NOW to protect its patented money-maker, years before it finds itself in the not-so-envious position of Pfizer, which fought on even after the bell rang on Lipitor (see "Pfizer Throws In the Lipitor Marketing Towel"). Note: Humira's U.S. patent expires in December 2016

With the filing of this petition, Abbott Labs may also take on another "crown" previously held by Pfizer -- the world's most hated pharmaceutical company. Good luck with that Abbott.

Booming Biologics
Abbott, however, is just the "poster boy" (or "patsy") chosen by the drug industry to take the shots by filing this petition, which really speaks for the entire industry. Patented biologics is a big business and represents the future of the pharmaceutical industry.

According to the WSJ, biologics "had $74.8 billion in U.S. sales last year, up 8.3% from the previous year, according to the IMS Institute for Healthcare Informatics. This year, seven of the 10 top-selling drugs will be biologics, with a total of $50.4 billion in world-wide sales, according to EvaluatePharma, which predicts that Humira will be No. 1 with $9.3 billion in world-wide sales."

"Low Hanging Fruit" Keeps FDA Busy & Out of Pharma's Social Media Hair

"Low Hanging Fruit" Keeps FDA Busy & Out of Pharma's Social Media Hair

Another tidbit I picked up this week at CBI's 3rd Annual Forum on Social Media Regulations and Compliance is the notion that the FDA is too busy going after the "low-hanging fruit" of promotional violations to pay much attention to violations of regulations involving social media and other esoteric Internet "tricks" such as the manipulation of meta tag data.

This came up in a discussion I started about the use of meta tags to create organic search results that are effectively branded ads lacking the FDA-required important safety information (ISI). I discussed this in previous blog posts (Who's in Charge of Your "Invisible" Metadata? WARNING: Don't Invoke the "Invisibility Rule" and Are Organic Search Results Next on FDA's Chopping Block?):

Metadata is usually "invisible" content inserted within the header of the HTML code that creates a Web page. This includes a "description" of the page or Web site and keywords. Some of this information is used by search engines to find the page and include a description of the page in the natural search result.
When you do a Google search on "Viagra," for example, you will find a "sponsored" link (i.e., paid search ad) like this:



You will also find this unpaid natural search result:



BOTH the paid ad and the search result contain content that is written and controlled by Pfizer. The natural search result content that begins with "Learn about..." is exactly the content that Pfizer included in its "description" meta tag within the HTML code for the viagra.com home page. Google just lifted that content. Users cannot control this content, only Pfizer can -- by editing the meta tag.

A medical/legal/regulatory (MLR) expert in the audience said: "The fact that the FDA may not be pressing that issue right now is because of the low-hanging fruit." He went on to further speculate that even when FDA issues its long-awaited social media guidance this practice would not be addressed because the FDA is looking at "larger organic issues."

I contend, however, that the FDA has already addressed this issue in a notice of violation (NOV) letter to Novartis regarding the use of meta data to create a "Facebook Share" social media widget that generates Novartis-created information for Tasigna that can be shared with Facebook users (see Implications of FDA’s Warning Letter to Novartis Regarding Facebook Share Widget). Organically speaking, this seems to be equivalent to using meta data to create a search result as described above, no?

Branded Tweets Lacking ISI: What's FDA's Thinking on This?

Branded Tweets Lacking ISI: What's FDA's Thinking on This?

This week, I attended CBI's 3rd Annual Forum on Social Media Regulations and Compliance in Alexandria, VA. Many of the medical/legal/regulatory (MLR) presenters and attendees were from smaller pharma and biotech companies such as Biogen, MedImmune, Astellas, Amarin, Ferring, etc.

In the absence of specific social media guidance from the FDA, several presenters tried to "navigate through current guidance and enforcement" to offer advice on how to develop a compliant social media strategy. This technique is what is often referred to as learning from "received precedent," which is a risky methodology considering FDA's past actions that have contradicted previously-accepted precedents (see, for example, "Death of the One-Click 'Rule' or 'Received Precedent' or Whatever!" and "FDA's Actions Speak Louder than Its Words").

One topic that was discussed by at least a couple of presenters was who controls the content on social media and, specifically, what content is pharma responsible for when it engages in social media conversations.

Glenn Byrd, Senior Director, Regulatory Affairs, at MedImmune, spoke about pharma accountability in his presentation. "At what point do we lose control of our content? When do we lose the responsibility [for content] so FDA does not come after us?" He cited "retweeting" as an example. As an non-social media example, Byrd talked about B-roll video, which pharma companies often provide to TV news stations when they are doing a story about a newly released product. "They [the news outlet] take it and they do whatever they want with it," said Byrd.

Of course, the B-roll itself must be compliant with FDA regulations. If it mentions a drug name and its indication, for example, it must also provide the important safety information (ISI) just as if it were a direct-to-consumer (DTC) ad.

But pharma companies are using Twitter to tweet about brands and their indications WITHOUT including any ISI. Take for example this LYRICA tweet that @pfizer_news sent just this morning:

This links to the press release, which has all the necessary ISI. It's as if Pfizer still believes in the "one-click rule" when it comes to tweets linking to press releases. The logic is this: there is no "received precedent" of FDA citing such tweets as violative, therefore it is perfectly OK for us [Pfizer] to do this.

Note that the tweet has been "retweeted" at least 8 times and cited a "favorite" tweet at least 3 times. The tweet has also been posted to the Pharma Marketing "News From the Pharma Industry" Forum (see here) where anyone can post a "reply" message. Thus, an ongoing conversation out of Pfizer's control can result from this tweet on Twitter and on discussion boards. That is the viral nature of social media.

While Pfizer cannot be held responsible for the retweets of its branded tweet or the conversations it may start elsewhere on the Internet, it should be held responsible for the original tweet, which is similar to the search ads FDA cited as violative in 2009 (ie, lacking important safety information).

What do you think?

Pharma Urged to Employ Wikipedia Editors: Ain't Goin' to Happen

Pharma Urged to Employ Wikipedia Editors: Ain't Goin' to Happen

My friend, Dr. Bertalan Meskó (@Berci) writes (here):

Dear Pharma Companies,

The place of Wikipedia in the dissemination of medical information online is indisputable now. If you want your customers to access information about your products from the quality perspective and in the simplest way, you have to deal with using Wikipedia.

Based on the pretty negative past encounters between pharma employees and Wikipedia editors (pharma employees trying to edit entries about their own products in a quite non-neutral way), we advise you to employ a Wikipedia editor if you want to make sure only evidence-based information is included in entries about your own products. Appointing someone from within your company as a “spokesperson” in Wikipedia who would perform all edits on behalf of the company is an excellent way to update those entries.

For more details, please see our open access social media guide [see my review here].

But basically, we, Wikipedians, are more than open to starting a discussion about this with you.

I’m looking forward to working together.

Dr. Bertalan Mesko
Webicina.com

I respect Berci and agree that pharmaceutical companies should employ full-time resources to monitor social media sites like Wikipedia and submit what they consider "corrective" information about products. But, IMHO, it ain't goin' to happen!

Boehringer Ingelheim (BI) responded to Berci via Twitter: "We look for patient safety issues & react. Its important to stick to Wikipedia policies too, so all transparent." But when asked by Berci if BI had posted anything online about this, BI responded "No at this point in time we have not....yet," seemingly leaving the door open.

But I am sure that no pharma company will ever -- in this economy -- hire someone just to monitor Wikipedia and write Wikipedia entries.

But why stop at Wikipedia? There's are other social media platforms that also need dedicated resources -- such as Twitter, Facebook, numerous patient discussion boards, and now Pinterest.

Many brand managers have probably hired outside agencies to monitor what people are saying about brands on social media sites, but the goal is not to issue "corrective information." It's more a matter of market research and measuring share of voice, that sort of thing (maybe also actively monitoring for safety issues as BI mentioned). These agents are temporary help and the companies will never hire anyone to do this full-time in-house. In fact, many social media pioneers within pharma companies have "moved on" (ie, lost their jobs); see, for example, "Is There an Upward Career Path Within Pharma for Social Media Pioneers?"

Big Pharma Dumb ALECs: J&J, Pfizer, GSK, Bayer, Novartis, Merck, Daiichi Sankyo, Sanofi-Aventis, PhRMA

Big Pharma Dumb ALECs: J&J, Pfizer, GSK, Bayer, Novartis, Merck, Daiichi Sankyo, Sanofi-Aventis, PhRMA

On June 6, ColorOfChange -- the nation’s "largest Black online civil rights organization" whose stated goal is to "strengthen Black America's political voice" -- launched a radio campaign that drew the "connection" between pharmaceutical company Johnson & Johnson (JNJ) and the American Legislative Exchange Council (ALEC), "the shadowy policy group that has worked to suppress the Black vote and push so-called 'stand your ground' laws nationwide" (see press release here).

Shortly afterward, JNJ pulled out of ALEC, saying it does not "condone legislative proposals that could serve, even inadvertently, to limit the rights or impact the safety of any individual" (see Star-Ledger editorial: "Johnson & Johnson right to pull out of ALEC"). The Star-Ledger pointed out that JNJ "has also had some ethical cleanup to do, and not just for being part of these ALEC initiatives."

The Star-Ledger describes these initiatives:

"The group [ALEC], which crafts model legislation to advance the interests of its corporate members, has promoted a flurry of bills that erode basic rights. Such as its measures to toughen voter identification requirements around the country, which disenfranchised the poor and the elderly without any real evidence that voter fraud is even a problem. And its dangerous "Stand Your Ground" laws, which basically allow anybody to use deadly force in purported self-defense, sometimes without even having to stand trial -- like the Florida law that initially prevented any prosecution in the Trayvon Martin case."

Don Bohn, Vice President of U.S. Government Affairs at JNJ, is still listed (as of 14 June 2012) as a member of ALEC's "Private Enterprise Board" (see here). I realize it takes some time to update a Web page, but deleting one name on a static Web page list is a no-brainer. Therefore, I hope JNJ truly distances itself from ALEC and cleanses its name from the list TODAY!

"Johnson & Johnson is the first business in New Jersey to wise up about ALEC, and it shouldn't be the last," said the Star-Ledger. Other ALEC big pharma members cited by the Star-Ledger include: Novartis, Merck, Daiichi Sankyo, Reckitt Benckiser Pharmaceuticals and Sanofi-Aventis (see a complete list here and here).

I was able to find some details about a few of ALEC's remaining Private Enterprise Board members:

Robert Jones
Director Government Relations & Public Affairs for Pfizer
LinkedIn page

John Del Giorno
VP Gov Relations at GSK
LinkedIn page
SourceWatch

Sandy Oliver
VP Public Policy & Government Affairs at Bayer HealthCare
LinkedIn page

Jeffrey Bond
Senior Vice President of State Government Affairs, PhRMA
PhRMA was a 2011 recipient of ALEC's Private Sector Member of the Year Award and a "Chairman" level sponsor of 2011 ALEC Annual Conference, which equated to $50,000 in 2010 (see here).

I wasn't able to find any of these executives on Twitter, but I have asked a few of them to connect with me via LinkedIn. I found out that Pfizer's Robert Jones has been a registered lobbyist in Texas since 1995. Here's a glimpse of his profile (found here) showing how he spent his money "lobbying" Texas lawmakers:

This is just a small peek into the life of pharma lobbyists. Obviously, they spend a lot of time wining and dining, which was something pharma sales reps used to do, but can't do any more!

BI Dumps Celebrity COPD Spokesperson and Seeks Inspired Facebook Fans Instead

BI Dumps Celebrity COPD Spokesperson and Seeks Inspired Facebook Fans Instead

Today Boehringer Ingelheim (BI) sent out this tweet: "We have just launched a new #hcsm activity within Facebook....want to find out more? Check out all the details here http://t.co/gwLgMe0D"

The link leads to "COPD Inspirations - The BIG Picture," a FaceBook page that encourages fans to submit images that reflect "the positive fight against COPD and will inspire others to take back control of their lives. So to get involved 'get creative, get emotive, get artistic!' and upload your image," says BI.

Recently, BI handed over the keys to its public health initiative, Drive4COPD, to the non-profit COPD Foundation (see here). That initiative features racecar driver/celebrity Danica Patrick who is more well-known as a swimsuit model and expletive-deleted competitor (see "Pharma Celebrity Spokespersons: Unrepentant, Secretive, and (Expletive Deleted)!").

BI's new Facebook-based COPD awareness initiative/campaign may signal a trend away from the use of paid celebrities to the exploitation of real patients, who will not receive any compensation whatsoever for the use of their images and stories. BI will, however, offer entrants a chance to win an iPad 2. (Why not a third-generation iPad? Perhaps BI has a surfeit of iPad 2's they need to get rid of.)

Here are the eligibility requirements:

1. Entrants must be aged 18 or over. 
2. Entrants cannot be employees of Boehringer Ingelheim (BI), or respective affiliate companies / be an employee of any pharmaceutical company 
3. Entrants must have a personal connection to COPD – i.e. either have the disease themselves, or be a carer / friend / family member of someone who has or has previously suffered with COPD. 

Oh, I forgot to mention one other criterium for eligibility: you must be a Fan of BI on Facebook. So BI gets new fans and free images for its COPD campaign. Sweet!

Since I was eligible -- my mother-in-law, Irene, has COPD -- I thought I'd submit an entry and see what happens. It was pretty easy. I had a photo of Irene that I think is inspirational (see below):

Along with an image, BI requires entrants to submit an "inspirational" comment, so I wrote: "COPD does not stop my Mom-in-Law, Irene, from enjoying the beautiful world around her, especially when she is with her family. Her daughter, Debbie, took this photo while they hiked in Pine Creek Gorge, commonly referred to as the Grand Canyon of Pennsylvania."

While I was at it, I also posted the photo to my Facebook page (BI's terms and conditions have no qualms about me using my photo elsewhere). The terms, however, do state: "Each entrant grants a worldwide licence to BI to use the images in any way the companies deem fit (e.g. to feature any or all of the submitted images on their websites and/or in any materials it develops for media, HCPs or patients, with acknowledgement of the entrant. Images will be used by BI to highlight understanding and awareness of COPD. Again, the entrant may be contacted to provide further background to the imagery and will be notified ahead of use)."

The competition opened  today and will close on the 18th July 2012. So, hurry, and enter those photos or other creative images TODAY!

Pfizer's Deceptive "Campaign Against Migraine" Tweet Deleted - Too Late!

Pfizer's Deceptive "Campaign Against Migraine" Tweet Deleted - Too Late!

Sometimes, you make a mistake and want to "take it back." I understand that. But this electronically-connected world in which we live is making it much more difficult to truly delete e-mails, text messages, and tweets from the network.

Take, for example, this tweet by @Pfizer_news:

This is how the tweet looks as posted to the News Direct from the Pharma Industry Forum of Pharma Marketing Network (here), which I own and "curate"/administer.

This is how I keep up with tweets from major pharmaceutical companies: I use my forum software to automatically scan the Twitter feeds of selected pharma companies and post tweets from these Twitter accounts to the above forum. Because I am "subscribed" to this forum, I get daily email notices whenever these posts are made. That's how I learned about this tweet from @Pfizer_news.

It seems like an innocent enough Tweet and looked interesting - I wanted to see what the "campaign for migraine relief" was all about, so I clicked on the link in the tweet: http://t.co/dhp1shpv, which is Twitter-shortened link.

I was surprised when the link above took me to http://www.relpax.com/, which is the branded website for Pfizer's Relpax migraine drug. I found nothing there about the "campaign for migraine relief" as was promised by the Tweet. That's the deceptive aspect of the Tweet.

The tweet included the hashtag #CampaignAgainstMigraine. A Google search on "CampaignAgainstMigraine" leads to a real "Campaign Against Migraine" Web site sponsored by Pfizer:

NOTE: If you search on "#CampaignAgainstMigraine" you can find reference to the same tweet. The link, however, leads to http://inagist.com/, which no longer lists the tweet.

So, what's the big deal? Obviously, it is deceptive to link to a drug.com site as part of a message that implies you will be joining a campaign against a debilitating medical condition! Hopefully, grownups at Pfizer recognized this mistake and deleted the tweet. But, as I said in the beginning, the tweet lives on -- at least on the Pharma Marketing Forum mentioned above.

Followup (8 June 2012): @Pfizer_news "retweeted" with the CORRECT link this time: "Join the campaign against migraine. bit.ly/KcaV5i #CampaignAgainstMigraine" As I suspected, the link is to the site I found via Google, not to the REPLAX branded website. Hat tip to Amber Williams (@williaqj) for alerting me.