We can't do that ! We're a regulated industry.

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DTC marketers are great at coming up with a myriad of excuses why they can't do things because the FDA regulates the DTC industry. The truth is that there are many ways to connect with customers using Web 2.0 that will keep even the most conservative legal and regulatory people happy. We're all paid to take risks and part of that risk taking is working with internal resources to make them understand that the battlefield has changed.



Over and over again when I recommend tactics in my consulting work I hear the phrase "I'll never get this passed regulatory or legal". There job is to protect your brand, and company, from making mistakes and getting letters from the FDA. The FDA, however, does not fully understand the Web and has not issued any in depth guidelines for DTC advertising on the Internet. I am sure that eventually they will get around to issuing guidelines for DTC advertising on the Internet but for now marketers should be leading the way into these uncharted waters.


Take a step back for a moment and put yourself in consumers shoes:


-Avandia and Actos are going to receive black box warnings.


-Nexium and Prilosec said there medications do not cause increased risk for heart attack.


-Vioxx litigation continues.


-Celebrex has enough fair balance to scare away anyone from ever taking NSAID's.


-The maker of oxycontin paid a record fine for misleading marketing.


-Doctors are continually accused of being in the "back pocket" of pharma.



With all these media stories where do consumers and patients turn? To their physician? CNN.com this week ran an article on "when to fire your doctor" and one of the key points is that patients should fire their physician when he/she doesn't spend enough time with you or explain things in language you can understand. Yet millions of dollars are wasted on the same old DTC programs that don't take into account that the public maybe becoming more and more skeptical of marketers messages.


You can interact with your target audience and patients believe it or not. You can use your thought leaders to talk to patients and consumers if your transparent and make it known that the physician you are using is a thought leader. What you can't do is continually push messages to an audience and expect them to trust your claims. They WILL research your claims and talk to each other and more importantly they will listen to each other. Just go to any message board and see what your patients/customers are saying to each other.


So how do you interact with these people? The first step is to get out of the mind set of mass marketing. Mass marketing is as dead as Brittany Spears career. You need to think of segmentation down to every branch possible. Once you do this you then need to identify the key influencers within each segment and come up with a strategic and tactical plan to reach these influencers and turn them into brand advocates. Yes this will take a lot of work but it will save millions of dollars in advertising and could provide a great ROI. There are a number of services out there that can measure the key channels that influencers use. Use this information to win these people over and you will be surprised at the results.


Once you have a program in place to reach influencers and turn them into brand advocates the next step is to determine which brand touch-points provide the strongest call to action. HINT: TV doesn't provide the strongest call to action. Cialis is back on air yet the traffic to their website remains flat during this campaign. That tells me that the current campaign is not providing the maximum ROI. You need to look at new touch-points including patient marketing events, events in conjunction with a local physician or medical center, and of course chats on the Web. Marketing today is a lot more about telling a story and building an emotional connection than a 60 second spot can convey. Remember your asking people to take something into their bodies and they don't trust you or your product.


Finally acknowledge weaknesses as well as strengths. If your product causes backaches then be upfront about it and inform people that with continued use the chance of getting a backache diminishes. Don't hide side effects let others communicate about the good and the bad of your product. Use the Web to bring people together rather than push information out there where it's beyond your control.


There are a lot of things DTC marketers can do to transform the state of DTC marketing but they are probably too busy developing and editing Power Point presentations over and over again. Bob Dylan once sang "the times they are a changing'" but it seems that in pharma marketing time is standing still.

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