FDA Hearings: Will a lot change in DTC marketing ?

The most important factors in health engagement are trust, authenticity and satisfaction. Drug companies rank very low in all three with consumers. (click to enlarge)

Then of course there is this little aspect called budgeting. Most, if not all, DTC marketers are seeing their budgets cut for next year and from my contacts within the industry a lot of the budget cuts are being applied to ( you guessed it) the Internet. The irony is that you can DO a lot more with a lot less money on the Internet but all too often the budget drives the strategy.

Physicians and other HCP's continue to be important sources of
healtcare credibility.

The FDA is not sure what guideline apply to social media and frankly a lot of drug companies are afraid that the FDA could allow limited marketing, via social media, because it means that they have more to do without knowing how to do it. It also means the potential of having someone within the department having to monitor social media for adverse event reporting if the site is an "official site". I believe Forrester recommended that to decrease this risk companies could eliminate two-way communication but others like GSK, who recently had a series of conference calls with ITP sufferers and a HCP, are willing to learn and listen.

The other aspect is that social media is evolving as we speak. Now keep in mind that the FDA still considers product websites as "labeling" and that 99.9% are more promotional than standard labeling. Will Twitter still be here in 3-5 years? Will Google's Wave jockey for the number one position combining social media and eMail? Who knows but in his book "The Next Evolution of Marketing" Bob Gilbreath mentions that since social media has allowed advertising its use has declined by consumers. Ultimately it is consumers who will decide what social media platforms survive but one aspect of marketing if more true for pharma today than before and that is they have to allocate resources to the channel, and platform, that has the biggest number of eyes and reach.

The real issue is not the FDA guidelines on social media but DTC marketers continued reluctance to embrace the realities of online marketing and empowered consumers (push vs. pull marketing). There continues to be tons of data out there on the importance of online marketing yet has anything really changed within online pharma marketing? Agencies want to present at the FDA because if the FDA gives the thumbs up to social media they see a huge upside potential for more work even though having an agency do your social media strategy is like having someone else speak for you at the dinner table.

From an industry POV they don't have the resources to dive into every new social media presence. You're talking about companies that have to have meetings to have meetings. By the time they could implement it might be outdated. The advantage however is they get to learn from others like Gardasil who are making an effort to connect consumers and patients over a serious health issue. The research we conducted with patients and consumers indicated that consumers want to brought together to share experiences however other sources of research also show that they do not take the word of other consumers too much when it comes to their experiences but again the seriousness of the health condition has a lot to do with that.

While spending over 10 years working in pharma and medical device companies I have learned that change is evolutionary not revolutionary. I still remember the conversation one of my managers had with me telling me to "slow down and let others catch up with me". That led to the development, for education purposes, of a lot of Power Point slide decks to teach people about the need to change marketing thinking to embrace empowered patients. That, in turn , got more people to support me and allowed me to do things like having a message board on Sarafem.com and having an online chat with a nurse via Cialis.com to have her make an appointment with a physician to talk about ED.

A VP at one of the top online health agencies once told me "pharma has a lot of skeletons in the closet and has a closed mind when it comes to hearing the truth". There are a lot of pharma companies that won't even let their people read BLOGs that are Google based or access Facebook & Twitter via the company Internet (some very big ones in fact).

So what do I expect from the FDA open hearings? A lot of self promotion and more this is what we need to do with research that has been out there for ages. But the fact that they are having these hearings communicates a lack of understanding of how people are using the Internet for health information. It also shows that DTC marketers still don't get it for the most part.

Does the FDA need to protect consumers from themselves and from drug company marketing or are consumers smart enough to challenge information and search for the credible health information? My guess is no matter what comes out of the FDA hearings we won't see a lot of change within DTC marketing. I expect next year at this time the Nightly News will still be chock full of drug industry TV ads.

Some companies may experiment or dabble in social media but forward thinkers who know that the time is right for engagement will be attending more and more conferences next year and asking "why can't we do this?"

Tags: FDA Hearing