In February 2004, the US FDA’s Division of Drug Marketing, Advertising and Communications (DDMAC) drafted guidelines governing the creation of unbranded websites, which spelled out rules that marketers should follow. Breaking a number of these rules resulted in Novartis receiving warning letters from DDMAC back in April about two of the company’s unbranded sites: www.gistalliance.com and www.cmlalliance.com.

Where Did Novartis Go Wrong?

Both Novartis sites were deemed to be overtly promotional of the Novartis therapy, Gleevec. Here’s where the sites went wrong:

• Promoted the use of Gleevec outside its indication and made unsubstantiated dosing-related claims
• Were “perceptually similar” in terms of color schemes and layout to the Gleevec site
• Included “representation or suggestion relating to a particular drug,” including: direct links to the Gleevec product website; references within a publication on the site to a pivotal Gleevec trial; and footnotes on the site that referenced imatinib (Gleevec’s established name), and prominently featuring the Novartis logo
• Did not provide fair balance. While unbranded awareness and education programs are not subject to fair balance requirements, the FDA has taken the stance that it is required if the unbranded program “impliedly identifies a particular drug”
• Mentioned a tyrosine kinase inhibitor (”TKI”) for the first line treatment of GIST and CML. Gleevec is the only TKI indicated for first-line treatment of chronic phase CML, and the only TKI indicated for first-line treatment of GIST
• Contained registration opt ins without being clear they were opting into receive “product information” that delivered Novartis communications, promoting Gleevec

Following the Rules

If you’re looking to develop an unbranded or disease awareness website, be sure to adhere to the guidelines outlined by DDMAC:

• Be clear, accurate and reinforce a public health message
• Refer consumers to an HCP for more information
• Ensure the unbranded experience has its own creative identity
  • Use a separate color palate, as well as different visuals and models, from the branded experience
• Review treatment claims as if the piece was branded
• Follow the same strict regulatory guidance in the way the statements are crafted and substantiated
• Provide balanced treatment discussions
• Provide clear opt-in options for consumers, including a double opt in procedure

Following the rules not only helps you avoid a warning letter, it allows you to capitalize on an opportunity to better educate and enhance the value of your sites. In short, you can break through the clutter without breaking the rules!

On July 29, 2010 the FDA issued a warning letter to Novartis for the Facebook share button and sharebar on the Tasigna product website – both consumer and HCP sides. The issue was that when a user clicked the share button, it displayed a post on the user’s Facebook wall. The post was a statement (that varied by page) that typically included the brand name and the indication. It was a brief statement with a link to the website, so of course it did not include fair balance. Further, language within the statement used on some of the pages used superiority language that FDA had previously told them not to use.

So, what does this mean?

First, just as in the instance of the Gleevec unbranded letters this spring, it actually changes nothing. Novartis, for the second time this year, simply violated known and understood DDMAC policies. It’s shocking, actually, that after the unbranded letters, that they did not do a better job following well established rules in the rest of their communications (particularly interactive communications).

This letter is certainly NOT a new FDA policy prohibiting the use of share tools or social media in branded pharma. It does reinforce the FDA policies regarding claims and balance and that channel and format does not change the rules. As with all things, the devil is in the execution.

What concerns us, is that, as with the unbranded Gleevec letters, the industry will overreact and start pulling back on their investments or efforts within social media. This should not be our response; we should take this as confirmation that DDMAC sees the internet and social media the same as every other channel and applies the same rules. We as an industry just need to accept that fact and follow the rules!

New Name Reflects Greater Breadth of Agency Solutions

PRINCETON, N.J., July 22, 2010 — Compass Healthcare Communications announced today that it has changed its name to Compass Healthcare Marketers.

“We realized that our company name needed to better reflect the type of organization we are and the breadth of services we offer our clients,” said Peter H. Nalen, President and CEO of Compass Healthcare Marketers.

Acknowledging that “communications” can be a general and somewhat misleading term, Nalen went on to emphasize that Compass serves as a true marketing partner to its clients. While communications solutions are, in fact, part of the agency’s service offerings, Compass equally provides critical marketing strategy and execution solutions.

“Marketing has and always will be central to who we are,” noted Nalen. “We focus first and foremost on providing smart marketing solutions for our clients. We then consider the necessary medium required to optimize results.”

Compass Healthcare Marketers offers a full range of marketing services for healthcare companies including interactive programs, analytics, relationship marketing, public relations, and branding programs.

About Compass Healthcare Marketers — www.compasshc.com

Compass Healthcare Marketers is a leading, full-service marketing communications agency focused on specialty healthcare companies. We develop innovative marketing solutions that help improve the health of people with serious and chronic conditions such as diabetes, pulmonary hypertension, melanoma, and hemophilia. Our reputation as smart marketers stems from our strategic approach to marketing, which includes building insightful analytics into every program we develop. These strengths, combined with our company-wide belief in honesty and integrity, are what drive our organization and keep our clients coming back.

At Compass, we believe that a brand is not a benefit, a formula, a name, or a logo. A brand is a contract with your targets.

Our job as marketers is to create and articulate your brand’s identity so that it is interpreted by each of your targets on terms that are relevant to them in their lives. Your brand’s name, logo, and graphics are tangible expressions of this identity while your brand’s promise, personality, and tone, are intangible expressions.

How do you develop your brand so it will grow and become a valuable asset to each of your targets?

The answer to this question is much different today than it was even five years ago. Why? Because of the Internet. The Internet has allowed us to think in and market to multiple targets and segments. Your brand may have to appeal to several very different audiences, each of which has a different set of expectations, perspectives, and reasons why they have come to interact with your brand.

These target audiences are the ones who define the relationship with your brand and what it will and will not mean to them. Another way to think about this is: What do your target audiences say about your brand when you’re not in the room? What do they believe to be true about your brand? Because it’s what they believe, not what you intend, that matters.

Consider these statistics:

• 25% of search results for the World’s Top 20 largest brands are links to user-generated content. (Source: Marketing Vox and Nielsen BuzzMetrics SES Magazine June 8 )
• 34% of bloggers post opinions about products & brands. (Source: Universal McCann’s Social Media Research Wave 3)
• 90% of consumers trust peer recommendations. (Source: July 2009 Nielsen Global Online Consumer Survey)

The communication of your brand—or where your targets learn about it these days—gets a bit tricky. This is especially true online, which is generally the first place your audiences will be introduced to your brand. Many aspects of communicating your brand online are not in your control, especially with the advent, growth and strength of social media. So make sure your intended brand identity is consistent among all your targets wherever you mention it. Know that others may take it and redeploy it—possibly into areas that you may not have even considered.

The Internet also allows you to target and reach each of your segments with the exact message you know your audiences will find valuable about your brand. It is the one medium through which you can deliver a direct, unfiltered definition of your brand and the experience your brand represents—the whole story with less interpretation—keeping it as true as possible to each segment that views it.

Here’s how to do it:

Think in multiples: Multiple segments. Multiple audiences. Multiple interpretations (because now you can). The question is no longer: What is the one message I want to convey? It’s: Who are the multiple segments interacting with my brand? Once you determine this, you need to understand how each segment wants to interact with your brand—on the phone, online, in person—and when they need the information.

Because you can now position your brand to multiple customer segments, you should do your segmentation research when you begin your branding research—even as early as Phase III and label design—and not afterward. Use the segmentation research to identify criteria on which your audience clusters (eg, practice areas, specialties, etc). Explore not only what your key message drivers are, but why, which is the most valued, and how will your messaging be delivered to each segment. Different segments respond to specific articulations of your brand’s identity. Emphasize nuances within your brand’s promise, personality, or values while making sure to maintain consistency on the external expressions. They are like pieces of a jigsaw puzzle that when put together, need to consistently display your brand’s identity. If your pieces are different or disparate, that puzzle will be a mess.

As your message and brand architecture are developed, make sure they are on a flexible platform that can be translated into multiple mediums to different segments—all while ensuring consistency in your brand essence. Next, develop strategies for each segment to receive messages in the form most suitable to them.

None of this is easy and it can’t be learned overnight or performed by older, more traditional agencies. It takes years of living in the segmented marketing world to be able to successfully build and promote a brand in it.

Innovation Lab Panelists

Alan G. Reicheg, SVP Commercial
Operations, Qforma

Devin Paullin, Ex. VP, Business
Development, Physicians Interactive

Mary Anne Greenberg, President
Alliance Healthcare

Michael J. Laferrera, Sr. Vice President,
Sales and Marketing, J. Knipper & Co.

Everywhere in the industry these days, you hear talk about Healthcare Professional Relationship Marketing (HCP RM), Non-personal Promotion (NPP), and Channel Preference Marketing (CRM). Nearly every company has these programs on their “to do” list, but few are actually implementing them. Why is this? On November 4, 2009, Compass Healthcare Communications hosted its Innovation Lab Series workshop in Princeton, assembling a team of participants and expert panelists to discuss this very topic.

HCP RM: Why Now?

The old model for how to target and communicate with healthcare professionals has been turned on its head. The time physicians have to interact with sales forces continues to diminish and access to physicians is becoming increasingly difficult. Up to 35% of all physicians are now considered “no see” docs and some states such as Massachusetts are imposing restrictions on sales rep activities. Add to this the fact that pharmaceutical companies are drastically cutting their sales forces and you have an environment that’s ripe for new and more effective ways to reach HCPs.

What HCP RM Is Not

Before exploring HCP RM programs in more detail, it helps to establish a few things that HCP RM programs are NOT. They are not newsletters or mailers or phone calls created in a remote conference room and then force-fed to a recipient. They are not comprised of generic content that makes no provision for how the recipient wants to be communicated with, what his or her level of knowledge is with the brand, or where the recipient resides along the brand adoption continuum. They are, instead, customer-focused programs, delivering the right message to the right audience segment at the right time using the right channel. The right message is one that is meaningful to the HCP. Figuring this out means understanding who the HCP is—what their needs and interests are, what motivates them—so that you can truly service their needs, not just sell them stuff.

Where To Start

When many pharma marketers hear the term relationship marketing, they are quick to think of patient relationship marketing efforts such as compliance programs. But given that some physicians either cannot or do not want to meet with reps and that many prefer other and more varied forms of contact, it’s clear that HCPs want to engage with the brand through several communication channels.

Building a successful HCP RM program is no easy feat. It all starts with understanding the different segments of your audience and delivering tailored, meaningful communications to them in the form, method or vehicle they prefer. Every disease state and therapeutic class is different. Organizations will have to adopt a different mindset beyond just a rep knocking on a quickly closing door. And there are no simple formulas that will guarantee success in any given specialty. But there are some best-practices tips we discussed over the course of the Innovation Lab session that can help overcome common challenges in the HCP RM space.

1. Identify leadership, budget, and resources: One of the biggest challenges to implementation, especially in larger pharmaceutical companies is: Who is going to lead the initiative? Who owns this “new” program? The brand? The sales force? Another party? Who will pay for it? And what changes will need to be made to the technical infrastructure to support the program? This may prove to be the biggest obstacle. A truly effective RM program should be thought of as an infrastructure investment; not a mere campaign. By its very nature and considering the many departments that an effective RM program impacts, this initial step has the highest likelihood of derailing or significantly delaying the entire project. Our advice is to pilot a program with one or more brands that share the same specialist. Do not go “enterprise wide” right out of the gate. Learn from the mistakes that were made with the adoption of online programs in Pharma. (See sidebar)
2. Devise the right segmentation strategy: Who are the right and wrong physicians for your program? What are the best messages to deliver to your different audience segments? To succeed in this area, you’ll want to work with outside resources to “really” understand your audience segments. Successful programs are based on segmentation that’s psychographic rather than segmentation that’s demographic, script-driven, or decile-driven. It’s important, too, not to forget the nurse segment, as nurses perform most of the legwork and patient interfacing. By first effectively segmenting HCPs and determining your goals, you can then move onto choosing the appropriate tactics and channels for those various segments.
3. Build the right databases. Having a database that meets your RM goals is key to delivering customized communications to each specific audience segment. Successful and strong relationships can only be attained when the database can continually “learn” and react over time. Pharmaceutical companies are notorious for having physician databases that are anything but robust. And many lack the capability to appropriately design, build, and maintain the right kinds of databases. Unfortunately, many vendors who excel in this area have proprietary databases that pharma companies can only rent, preventing the pharma companies from truly owning, mining, and leveraging its own data. Still, there are tips for creating an effective database. It’s essential, first of all, to set up your database correctly from the beginning, ensuring that the data fields you collect are indeed the right ones and that the right people are using the database. It‘s critical, too, that the database be designed to acquire and decipher incoming information—eMails opened, poll questions answered, site pages visited, rep observations—so that the database continually learns where each target is on the behavioral continuum and what is required to move them further along. This ensures that your communications meet the specific information needs of each segment, reflects their knowledge of the brand and where they are on the continuum. Your budget and technical requirements must also be able to support the data to be collected and stored.
4. Abandon political silos. Beware the turf battles that may ensue, although this may be easier said than done. Chances are, a lot of hands will be touching your RM program, and there will be many interested, affected and vested parties—from individuals in multiple internal departments to a network of outside vendors. This is not the time to retreat to political silos. These different teams need to work together and complement each other’s contributions. Pick the core competencies of each group and have them focus on the task at hand. Everyone needs to know how to play well together in order to deliver the best program results.
5. Address sales force fears. Nearly everyone would agree that the in-person relationships developed by the field force are the number one relationship marketing vehicle available. However, it’s not uncommon for sales reps and their management to view HCP RM programs with resentment. In reality, these programs aren’t intended to replace the sales force—ideally, these programs should serve to assist and augment sales force efforts. A successful RM program must be integrated with all the efforts put forth by the sales group, and be developed with their involvement at all levels. To do so, it is imperative that all parties see the value of the program from the beginning and be allowed to not only participate in the upfront design but also have direct access to all ongoing reporting and results.
6. Measure results. It’s amazing how many companies budgeting for HCP RM programs fail to invest in proper metrics. ROI strategies are key to analyzing which strategies and tactics worked, which didn’t, and which audience segments are worth investing in. It is hard to predict which tactic will work, and which path is most successful for each segment. There are no easy formulas for determining all this. At a minimum, everyone needs to identify and agree to specific measurement criteria before ever launching a single program. Given the pioneering stage of HCP RM programs and the number of variables involved, pre-program ROI analysis is difficult. Many times, a combination of models, formulas, and basic trust among your partners and internal measurement team is all that will suffice. You take your best collective guess ahead of time, implement a pilot of your program, and then closely measure the results.
7. Develop a program of tactics. This is not about eMarketing or Interactive Marketing, but about giving your targets another opportunity to engage with your brand. It’s less about selling and more about customer service. There is seldom one singular tactic that you can pursue at the expense of all others. Tactics should be regarded as an entire program. Thinking multimodal is key. We have to give physicians a chance to respond to determine their preference for not only the tactic but also how it is delivered. The good news is that physicians are already accessing some of the technology you’ll be using. An estimated 80% of all physicians under the age of 45 carry smart phones and nearly 1 in 4 participates in eDetail programs . There are many vehicles at your disposal—take the time needed to invest in the right ones.
8. Don’t lose sight of the message. If you’ve been delivering the same message to your audience for a while, changing the medium in which you communicate that message is not likely to have much of an impact. Concentrate instead on delivering information that’s new and meaningful to physicians. Translate those hours and pages of physician insight research into meaningful content that can result in behavior change. Find a balance between branded and unbranded communications. Focus on providing needed services to your audience versus simply selling yourself and you just might find yourself becoming the de facto expert in an area.

Clearly, HCP RM programs are growing in prominence. Finding success in this area requires understanding your customers like never before in order to offer them meaningful information and tools that they actually want to use. By integrating these tactics and resources so they all work well together you can successfully shift from the mindset of physician “selling” to one of physician “service.” Making that shift will strengthen your relationships with all your key targets—a critical requirement in moving HCPs closer toward ultimate brand loyalty.

Two tips to consider as your develop your HCP RM programs:

1. Develop a program of tactics. This is not about eMarketing or Interactive Marketing, but about giving your targets another opportunity to engage with your brand. It’s less about selling and more about customer service. There is seldom one singular tactic that you can pursue at the expense of all others. Tactics should be regarded as an entire program. Thinking multimodal is key. We have to give physicians a chance to respond to determine their preference for not only the tactic but also how it is delivered. The good news is that physicians are already accessing some of the technology you’ll be using. An estimated 80% of all physicians under the age of 45 carry smart phones and nearly 1 in 4 participates in eDetail programs¹. There are many vehicles at your disposal—take the time needed to invest in the right ones.
2. Don’t lose sight of the message. If you’ve been delivering the same message to your audience for a while, changing the medium in which you communicate that message is not likely to have much of an impact. Concentrate instead on delivering information that’s new and meaningful to physicians. Translate those hours and pages of physician insight research into meaningful content that can result in behavior change. Find a balance between branded and unbranded communications. Focus on providing needed services to your audience versus simply selling yourself and you just might find yourself becoming the de facto expert in an area.

¹ – Manhattan Research, 2009

HCP RM: Why Now?

The old model for how to target and communicate with healthcare professionals has been turned on its head. The time physicians have to interact with sales forces continues to diminish and access to physicians is becoming increasingly difficult. Up to 35% of all physicians are now considered “no see” docs¹ and some states such as Massachusetts are imposing restrictions on sales rep activities. Add to this the fact that pharmaceutical companies are drastically cutting their sales forces and you have an environment that’s ripe for new and more effective ways to reach HCPs.

What HCP RM Is Not

They are not newsletters or mailers or phone calls created in a remote conference room and then force-fed to a recipient. They are not comprised of generic content that makes no provision for how the recipient wants to be communicated with, what his or her level of knowledge is with the brand, or where the recipient resides along the brand adoption continuum.

They are, instead, customer-focused programs, delivering the right message to the right audience segment at the right time using the right channel. The right message is one that is meaningful to the HCP.  Figuring this out means understanding who the HCP is—what their needs and interests are, what motivates them—so that you can truly service their needs, not just sell them stuff.

Where To Start

When many pharma marketers hear the term relationship marketing, they are quick to think of patient relationship marketing efforts such as compliance programs. But given that physicians either cannot or do not want to meet with reps and that many prefer other and more varied forms of contact, it’s clear that HCPs want to engage with the brand through several communication channels.

Building a successful HCP RM program is no easy feat. It all starts with understanding the different segments of your audience and delivering tailored, meaningful communications to them in the form, method or vehicle they prefer. Every disease state and therapeutic class is different.  Organizations will have to adopt a different mindset beyond just a rep knocking on a quickly closing door. Finding success in this area requires understanding your customers like never before in order to offer them meaningful information and tools that they actually want to use. By integrating these tactics and resources so they all work well together you can successfully shift from the mindset of physician “selling” to one of physician “service.”  Making that shift will strengthen your relationships with all your key targets—a critical requirement in moving HCPs closer toward ultimate brand loyalty.

¹ – SK, A, 2009

The growth and usage of “new media tools” will always surpass and ultimately replace “traditional methods”. Smoke signals were replaced by guys with sandwich boards, who were replaced by newspapers, then radio then print and TV. There will always be a constant evolution. Marketing doesn’t change, the mediums that we use will always change, but at the end of the day, it is still marketing.

Having said that, how we approach marketing is changing, and quickly. In this past year we have heard a lot about Relationship Marketing or (RM). It was first discussed in the form of patient compliance programs, and most recently, given the changes in the sales force structure, size, and regulations, HCP RM. Both are the same, it’s about marketing to specific segments.

Segmented marketing the ability to identify and successfully reach and market to multiple different and distinct target audiences which has been pioneered and perfected by Interactive will continue to evolve as the marketing approach. In the past promotional campaigns consisted of leveraging one benefit into one message and then communicating that message through the reps, journal ads, and TV. The Intent has allowed us to think in segments. Going forward the agencies that will serve their brands best are the ones that internalize this approach across everything they do, from label design to brand messaging to all the promotional activities.  It is no longer what is the one message, it’s which segments do I want to reach, influence, empower; how do they want to consume my message (with or on the phone, online, in person, etc) and when do they need the information?