Pharma Social Media Trials & Tribulations


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Presentation made at the PharmaMarketing Summit 2012 in Chicago in April, 2012.

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Pharma Social Media Trials & Tribulations

  1. 1. Pharma’s Social Media Trials and Tribulations Presented 2 May 2012 at: Pharmaceutical Marketing Innovation Summit© 2012 Pharmaguy
  2. 2. 2   Pharma Embraces Social Media  Pharma and Healthcare Social Media Wiki*  >70 Twitter Accounts (excluding personal employee accts)  65 Facebook Sites (may be less post Aug 15, 2011)  38 YouTube Sites  37 Brand-Sponsored Patient Communities  10 Blogs   *Source: Dose of Digital Blog. As of May, 2011. © 2012 Pharmaguy
  3. 3. 3   First Pharma Discussion Board April 2006 GSK’s allowed consumers to ask questions and have an online conversation among themselves and with experts. GSK said the purpose of the site was to offer peer support and professional advice to dieters and to "dispel the many myths about dieting, exercise and fraudulent weight loss products.” In  June  2007,  GSK  launched   AlliConnect—the  first  pharma   product  branded  Blog—to   promote  Alli,  its  newly  approved   over-­‐the-­‐counter  weight  loss  pill.  © 2012 Pharmaguy
  4. 4. 4   First Pharma Sponsored YouTube Video October 2006 GSK (UK) sponsors “My Dad has Restless Leg Syndrome” YouTube video, which includes a message at the end stating that “My dad is one of a Million people in the UK who suffer from RESTLESS LEG SYNDROME.” May  2008:  Johnson  &  Johnson  launches   the  first  pharma  YouTube  unbranded   Channel.   September  2008:  FDA  issues  first   pharma  YouTube  video  warning  leCer   to  Shire  PharmaceuDcals  (Vyvanse).   February  2009:  AstraZeneca  launches   "My  Asthma  Story,"  the  First  Rx   (Symbicort)  branded  YouTube  channel.  © 2012 Pharmaguy
  5. 5. 5   Pfizer Collaborates with Sermo October 2007 Sermo and Pfizer sign a deal whereby Pfizer gains access to the online physician community via surveys and sponsored content. More importantly, Pfizer physicians can join Sermo and openly participate in online physician conversations as long as they identify themselves as employees of Pfizer. A Sermo press release characterized the deal as a "strategic collaboration designed to redefine the way physicians in the U.S. and the healthcare industry work together to improve patient care.” Only  24%  of  physicians  are  using  physician  peer   communiDes  like  Sermo,  Medscape,  DrConnect,   PhysicianConnect,  Ozmosis,  etc.    © 2012 Pharmaguy
  6. 6. 6   First Pharma Facebook Page June 2008 McNeil Pediatrics—a division of J&J —launches ADHD Moms. “Now to be fair, this Facebook page, still isn’t all that interactive,” said Marc Monseau, a J&J spokesperson. “Though visitors can download podcasts, articles and participate in instant polls, they can’t post comments to the wall on the page. What they can do, though, is use their own Facebook pages to connect with other ADHD Moms fans. It’s a baby step, to be sure, but I understand the team is looking at other steps they can take to make it easier for people to share their insights into caring for kids with ADHD.” © 2012 Pharmaguy
  7. 7. 7   FDA Sends 14 Warning Letters April 2, 2009 FDA sends 14 letters on a single day to major pharmaceutical companies concerning their Google and Yahoo Rx paid search ads. Letters were dated 29 March 2009, but made public on 2 April 2009. April  1,  2009:  Pharmaguy   posts  fake  press  release   announcing  FDA  guidance  on   pharma’s  use  of  social  media.   Previously  (December  2006)   Pharmaguy  said  “FDA  should   be  taking  a  closer  look  at  drug   promoDon  via  the  Internet.”  © 2012 Pharmaguy
  8. 8. 8   Roadside Casualty: “One-Click Rule” Jim Nail, CMO at TNS Media Intelligence/Cymfony, defined the “rule” this way: “...there is no ‘official’ FDA one-click rule...there is a ‘received precedent’ that if you have one click from your brand site to the PI or labeling information, that is acceptable. Or call it ‘best practice’. Or call it just ‘common practice’.” FDA’s 14 warning letters put an END to the one-click “rule”, “received precedent”, “best practice”, or “common practice,” said Pharmaguy. 16  November  2006:  First  instance  of  the  "one-­‐click  rule"   debated  in  an  open  forum.  At  an  industry  conference,  a   Google  presenter  encouraged  the  use  of  an  Adword  format   that  included  the  drug  brand  name  and  indicaDon  BUT  not   including  the  fair  balance  (major  side  effects)  saying  the  side   effects  were  just  “one-­‐click”  away.  Pharmaguy  challenged  the   speaker  and  said  such  ads  violate  FDA  regulaDons.   28  August  2008:  First  indicaDon  that  the  “one-­‐click  rule”  is  not   recognized  by  FDA:  FDA  sends  a  noDce  of  violaDon  le^er  to   NovarDs  PharmaceuDcals  regarding  Diovan  Web  banner  ads   that  fail  to  menDon  side  effects.    © 2012 Pharmaguy
  9. 9. 9 UCB Embraces Adverse Events on Sponsored Discussion Board June 16, 2009  Goal: Generate patient-reported outcomes that may help UCB better understand how patients live with epilepsy and help advance epilepsy care.  Provides disease tracking tools  Deployed a system for reporting adverse events to FDA “UCB has an ethical and legal responsibility to report adverse events associated with our drugs. If adverse events for any UCB drugs are mentioned on the site, UCB is required to report these directly to the U.S. Food and Drug Administration (FDA). Therefore, we are working to develop and deploy a solution that will allow us to assess and process potential adverse events, report them to the FDA, and capture them in the UCB safety database.” -- Peter Verdru, MD, UCB’s Vice President of Clinical Research© 2012 Pharmaguy
  10. 10. 10 First Pharma Rx Branded Tweet!   June 18, 2009 I called this tweet “Sleazy Twitter Spam” Challenge (US): How to fit benefits and fair balance in 140 characters or less? We’re Still Friends! Challenge (Globally): How to make it meaningful for patients © 2012 Pharmaguy
  11. 11. 11   FDA Announces Public Hearing   September 21, 2009 “This meeting and the written comments are intended to help guide FDA in making policy decisions on the promotion of human and animal prescription drugs and biologics and medical devices using the Internet and social media tools.” April  2,  2009:  Pharmaguy  issues   first  public  call  for  FDA  public   hearing  on  social  media.  “We   should  make  sure  that  when  it   comes  Dme  for  the  FDA  to   actually  create  a  guidance   document  on  social  media  that   it  does  it  with  input  from  ALL   stakeholders.”  © 2012 Pharmaguy
  12. 12. 12   FDA Hosts Public Hearing   November 12-13, 2009  Accountability  Fulfilling Regulatory Requirements  Posting Corrective Information  Links  Adverse Event Reporting  © 2012 Pharmaguy
  13. 13. 13   FDA’s Guidance Sausage-Making Process    Publish Intent in Federal Register.  Although NOT Required, Hold a Public Hearing.  Have a Public Comment Period.  Review Comments Submitted to Docket.  Issue DRAFT Guidance.  Collect & Review Comments on DRAFT Guidance.  Revise DRAFT Guidance Based on Comments, If Necessary and Issue FINAL Guidance. STILL WAITING!  © 2012 Pharmaguy
  14. 14. 14   Traffic Congestion Slows Down FDA   26 February 2010: Pfizer contends that FDA’s proposed social media guidance “raises First Amendment concerns.” Guidance, said Pfizer, is too vague and engenders “extensive litigation.” 15 June 2010: FDA says it plans to issue multiple guidance documents on Internet promotion. Sounds like they bit off more than they can chew. 28 April 2010: A series of proposed studies by the FDA designed to test different ways of presenting prescription drug risk and benefit information on branded drug Web sites may further delay issuance of social media guidelines by FDA. 21 May 2011: FDA Involvement in criminal investigation of Google may further delay social media guidelines. Pharmaguy speculates that there is evidence that the delay may be due to the ongoing legal case against Google and online pharmacies by the Department of Justice. 1 June 2011: FDA drops “Social Media” from its 2011 Guidance Agenda, but agenda hints that responding to unsolicited statements/requests on pharma social media sites may first guidance to be issued in 2011. 5 July 2011: Pharma Citizen Petition Filed. Asks for binding regulations – not guidelines – for responding to unsolicited requests for off-label information. FDA must respond to this before issuing guidance as planned. © 2012 Pharmaguy
  15. 15. 15 Roche Publicly Discloses Social Media Principles August 16, 2010 “A significant, albeit, small step in the direction of corporate transparency, normally so difficult to achieve within the pharma industry but so essential if it is to regain the trust that will be crucial for its long-term survival…[yet] so few pharmas have publicly revealed their social media policies. Why is the industry so reticent?” -- Len Starnes, Bayer© 2012 Pharmaguy
  16. 16. 16 Pfizer’s SM “Guard Rails” and Secret SM “Playbook” December 2010 Pfizer talks about a SM “Playbook,” but won’t let us see it. "The playbook and social media policy are constantly evolving,” said Ray Kerins, Pfizer’s Vice President of Worldwide Communications. “We thought we had it finished last December, and then we realized we didnt and we went back to update it. So, its constantly moving. While I dont want to say its proprietary, I also dont want to make too big of a deal about it because we call it common sense." Based on a U.S. Air Force Chart. Guides Pfizer Canada in responding to remarks on social media networks which are either the property of, sponsored by or have a relation of some kind to Pfizer Canada.© 2012 Pharmaguy
  17. 17. 17 Sanofi-Aventis & Patient Collide on Facebook March 15, 2010 The pharmaceutical industry’s worst fear was realized when a “disgruntled patient” posted multiple adverse event messages and photos on the wall of a Sanofi-Aventis Facebook page (VOICES). The page did not have comments turned off and did not include any terms of use. "A  precedent  has  been  set   by  this  experience,”  said   Pharmaguy,  “which  does   not  bode  well  for  the   future  of  pharma  social   media.”  © 2012 Pharmaguy
  18. 18. 18   Janssen’s Open Road Youtube Policy   June 9, 2010 "Heres a hint for pharma. Nothing will go viral if you dont allow Likes or comments. Guaranteed.” -- Jon Richman “Comments are reviewed before posting - in line with the commenting policy on the site. The vast majority of comments have been posted, Kind regards, Gary” -- Gary Monk, Product Manager.© 2012 Pharmaguy
  19. 19. 19 Janssen’s Open Road Facebook Policy   October 7, 2010 Publishes all comments before reviewing, but reserves right to delete comments if offensive or mention ANY product. © 2012 Pharmaguy
  20. 20. 20 First Pharmaguy Social Media Pioneer Award October 19, 2010 Alex Butler, Digital Strategy and Social Media Manager at Janssen & recipient of first ever Pharmaguy Social Media Pioneer Award, says: “moderation is about engagement, leading and responding to the community not censorship Negative comments r V valuable” “If you want to receive the benefits of SM engagement it has to be real, community moderate themselves in the end” “if a brand, company, person is that worried about comments in SM there is probably a deeper issue under the surface” © 2012 Pharmaguy
  21. 21. 21 First Live Pharma Twitter Chat February 16, 2011 AstraZeneca hosts a one-hour chat on Twitter to raise awareness about helping patients save money through prescription savings programs. Pharmaguy said, "This is quite gutsy of AZ considering that anyone can ‘join’ the chat simply by posting a message containing the #rxsave hashtag. And anyone can post messages about AZ drugs and mention side effects too even though AZ might say that it will not respond to questions about specific drugs.” © 2012 Pharmaguy
  22. 22. 22 First Hack of a Pharma Facebook Page July 20, 2011   Pfizer’s US corporate FB page broken into by “Script Kiddies.” Shut down for several hours over weekend.   Admin password “guessed” by hackers after finding a LinkedIn page of an outside PR agency person who was responsible for creating or overseeing the page’s development© 2012 Pharmaguy
  23. 23. 23 First Hack of a Pharma Facebook Page July 20, 2011  Pfizer promises to “share lessons” with other pharma companies.  Some lessons might include:   Make sure your passwords are strong & protected   Hire competent outside agencies (PR vs Interactive?)   Have competent in-house FTEs oversee SM agencies monitor SM sites 24/7© 2012 Pharmaguy
  24. 24. 24 Pharma Phases Out Facebook Pages August 15, 2011   New Facebook Policy: Pharma is no longer be able to shut off comments to pages   Among First to go: ADHD Moms (FIFO)   Then Janssen’s Psoriasis 360 page (April 2012) Are  some  pharmacos  using  this  an  excuse  to   shut  down  pages  that  have  not  been  effecDve?    © 2012 Pharmaguy
  25. 25. 25 Pharma Social Media “Flash Mob” August 19, 2011   GSK (UK) Facebook page experiences first-ever “flash mob” – an organized grassroots comment attack   SEROXAT SUFFERERS Blog posted these instructions: 1. Sign up to the GlaxoSmithKline Facebook page. [Do this by clicking the Like button.] 2. Open comments under the "Glaxo "Builds Bonnie Babies" advertising hoarding opposite Kings Cross Station, London in 1921, UK" thread. 3. Ask them a question about one of their products. 4. Sit back and watch consumer queries get deleted. © 2012 Pharmaguy
  26. 26. 26 BI’s “Famously Unpronounceable” YouTube Video September 20, 2011© 2012 Pharmaguy
  27. 27. 27 BI’s “Famously Unpronounceable” YouTube Video: #FAIL! September 23, 2011   Video set to “private” after PMCPA cited BI for Code of Practice violations related to its handling of real-life “parrots” – patient advocates, KOLs, & reporters   But video copied & re-uploaded by “razyparrot1000” – now gone viral!   Is it sexist? Was it approved at highest level? Did employees complain?© 2012 Pharmaguy
  28. 28. 28 Pfizer’s Chapstick Slapstick FB Fiasco October 27, 2011  A social media “death spiral” says AdWeek  Negative comments deleted without explanation  People complain about comments being deleted  Eventually (maybe too late!), Pfizer apologizes but tempers the apology by saying it only deletes “repetitive” & “spam-like” comments© 2012 Pharmaguy
  29. 29. 29 Pharma Employee Tweet Problem December 13, 2011  The Prescription Medicines Code of Practice Authority (PMCPA) ruled Allergan breached the Code on several counts after an employee accidentally tweeted publicly about Botox  Employee violated Allergan’s "Global Social Media Policy” that clearly stated "no Allergan employee might comment in a social media forum about Allergan products or business activity."  Should pharmacos make their SM policies public to be more transparent & accountable?© 2012 Pharmaguy
  30. 30. 30 FDA Off-Label Guidance & Social Media December 27, 2011  Section VI addresses responding to unsolicited requests on public forums such as the Internet and "emerging electronic media”  Cites cases on YouTube, blogs, and Twitter: Pharma should respond to unsolicited requests via private channels  “FDA recommends that sales and marketing personnel have no input on the content of responses to unsolicited questions or requests for off-label information”© 2012 Pharmaguy
  31. 31. 31 Novo Nordisk & Bayer on April, 2011© 2012 Pharmaguy
  32. 32. 32 Pharma’s Social Media Readiness 32 © 2012 Pharmaguy
  33. 33. 33 Advertising Vs. Sponsorship on Social Media Sites Is it appropriate to: •  Place clearly labeled product display ads on social network pages just as on any other Web page. •  Develop a Facebook page or forum on a social network site that indicates it is a sponsored page/forum. 33 © 2012 Pharmaguy
  34. 34. 34 Engaging Consumers via Social Media 34 © 2012 Pharmaguy
  35. 35. Resources     Social Media Pharma Marketing Readiness Self-Assessment --   Overcoming Space Limitations in Social Media; Use code ‘FDA397’ to get it FREE!   Accountability for Pharma Content on Social Media Sites; Use code ‘FDA497’ to get it FREE!   Solving the Social Media Adverse Event Reporting Problem; Use code ‘AE495’ to get it FREE!© 2012 Pharmaguy
  36. 36. Contact Me  © 2012 Pharmaguy