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Presentation made at the PharmaMarketing Summit 2012 in Chicago in April, 2012.
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© 2012 Pharmaguy
Pharma’s Social Media Trials and Tribulations
Presented 2 May 2012 at:
Pharmaceutical Marketing Innovation Summit
© 2012 Pharmaguy
2
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.
Pharma Embraces Social Media
© 2012 Pharmaguy
First Pharma Discussion Board
GSK’s QuestionEverything.com 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.”
April 2006
3
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
First Pharma Sponsored YouTube Video
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.”
October 2006
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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
Pfizer Collaborates with Sermo
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.”
October 2007
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Only 24% of physicians are using physician peer communiDes like Sermo, Medscape, DrConnect, PhysicianConnect, Ozmosis, etc.
© 2012 Pharmaguy
First Pharma Facebook Page
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.”
June 2008
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© 2012 Pharmaguy
FDA Sends 14 Warning Letters
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 2, 2009
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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
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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.
Roadside Casualty: “One-Click Rule”
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
“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
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
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UCB Embraces Adverse Events on Sponsored Discussion Board June 16, 2009
© 2012 Pharmaguy
I called this tweet “Sleazy Twitter Spam”
Challenge (US): How to fit benefits and fair
balance in 140 characters or less?
Challenge (Globally): How to make it meaningful for
patients
We’re Still Friends!
10
First Pharma Rx Branded Tweet! June 18, 2009
© 2012 Pharmaguy
FDA Announces Public Hearing
“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.”
September 21, 2009
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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
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FDA Hosts Public Hearing November 12-13, 2009
Accountability Fulfilling Regulatory Requirements Posting Corrective Information Links Adverse Event Reporting
© 2012 Pharmaguy
13
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!
FDA’s Guidance Sausage-Making Process
© 2012 Pharmaguy
14
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.
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.
© 2012 Pharmaguy
Roche Publicly Discloses Social Media Principles
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“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
August 16, 2010
© 2012 Pharmaguy
Pfizer’s SM “Guard Rails” and Secret SM “Playbook”
16
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.
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 didn't and we went back to update it. So, it's constantly moving. While I don't want to say it's proprietary, I also don't want to make too big of a deal about it because we call it common sense."
December 2010
© 2012 Pharmaguy
Sanofi-Aventis & Patient Collide on Facebook
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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
Janssen’s Open Road Youtube Policy
“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.
"Here's a hint for pharma. Nothing will go viral if you don't allow 'Likes' or comments. Guaranteed.” -- Jon
Richman
18
June 9, 2010
© 2012 Pharmaguy
Publishes all comments before reviewing, but reserves right to delete comments if offensive or mention ANY product.
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October 7, 2010
Janssen’s Open Road Facebook Policy
© 2012 Pharmaguy
“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”
First Pharmaguy Social Media Pioneer Award
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Alex Butler, Digital Strategy and Social Media Manager at Janssen & recipient of first ever Pharmaguy Social Media Pioneer Award, says:
October 19, 2010
© 2012 Pharmaguy
First Live Pharma Twitter Chat
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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
First Hack of a Pharma Facebook Page
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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
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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
First Hack of a Pharma Facebook Page
© 2012 Pharmaguy
Pharma Phases Out Facebook Pages
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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
Pharma Social Media “Flash Mob”
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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
BI’s “Famously Unpronounceable” YouTube Video
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September 20, 2011
© 2012 Pharmaguy
BI’s “Famously Unpronounceable” YouTube Video: #FAIL!
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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
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October 27, 2011
A social media “death spiral” says AdWeek
Negative comments deleted without explanation
People complain about comments being deleted
Pfizer’s Chapstick Slapstick FB Fiasco
Eventually (maybe too late!), Pfizer apologizes but tempers the apology by saying it only deletes “repetitive” & “spam-like” comments
© 2012 Pharmaguy
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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?
Pharma Employee Tweet Problem
© 2012 Pharmaguy
30
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”
FDA Off-Label Guidance & Social Media
© 2012 Pharmaguy
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April, 2011
Novo Nordisk & Bayer on
© 2012 Pharmaguy 32
Pharma’s Social Media Readiness
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© 2012 Pharmaguy 33
Advertising Vs. Sponsorship on Social Media Sites
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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.
© 2012 Pharmaguy 34
Engaging Consumers via Social Media
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© 2012 Pharmaguy
Social Media Pharma Marketing Readiness Self-Assessment -- http://tinyurl.com/caghnm
Overcoming Space Limitations in Social Media; http://bit.ly/fdasmSpace. Use code ‘FDA397’ to get it FREE!
Accountability for Pharma Content on Social Media Sites; http://bit.ly/fdasmAcct. Use code ‘FDA497’ to get it FREE!
Solving the Social Media Adverse Event Reporting Problem; http://bit.ly/fdasmAE. Use code ‘AE495’ to get it FREE!
Resources
© 2012 Pharmaguy
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