The Centers for Medicare & Medicaid Services (CMS) recently released its final guidelines for Stage 2 of Meaningful Use, the criteria that determine whether a healthcare professional’s practice or a hospital is eligible for Medicare and/or Medicaid electronic health record (EHR) incentive payments. So far, the government’s incentive program for moving over to EHRs seems to be working. According to a study published in the Journal of the American Medical Informatics Association, the Meaningful Use program has increased the adoption of EHRs with the highest rates coming from smaller hospitals.

However, even as the government continues to push the move to EHRs there is still a debate within the pharmaceutical industry about what their involvement in this space should be. That is also true of the electronic medical record (EMR), which is sometimes used interchangeably with EHRs. (EMRs are actually the medical records owned by the physician or hospital and contain just their record of the patient’s history, while EHRs are owned by the patient and contain his/her complete medical history with records, test results, etc., from all of the doctors and/or facilities where he/she has received care and can be shared with all of those facilities.) Since both are digital, it is possible to include advertisements and links to additional information or other services that were never possible with paper records. While this may seem like a great promotional opportunity for pharma companies, there are a few things that may hold them back and one of them is uncertainty.

“Today’s EMR market environment is a bit like the Wild West in the 1870s: Lots of action, a great deal of scrambling for dominant position, but no firm idea of what the future will look like,” says Chris Dowd, Senior Vice President, Market and Product Development at PSKW. “Currently, physician practices must select an EMR system from the roughly 300 different providers in the market, each of which offers its own mix of capabilities and limitations. There is no doubt that the landscape will be much different five years from now.”

One thing that pharma marketers do know, however, is that they must go where their audience is.

“Although ‘The Great EMR Settling Out’ has yet to occur, pharma has learned over the past 50 years that to be successful it must promote its products when and where physicians are active,” Dowd adds.

Panorama asked marketers to chime in on whether they would be open to using EMRs/EHRs as a promotional channel and what they would use it for. Just about all of our respondents agree that involvement with electronic records is fair game, but they also offered different insights into how it can be used. Panorama also polled physicians to discover exactly what they would want from pharma in this space.

Pharma Must Provide Value

The majority of our respondents believe that any industry involvement with EMRs or EHRs must involve some kind of educational or value-added service.

Mark Heinold
President, LDM Group

I would not support advertising within the “trusted digital space” of EMRs. However, I do believe that utilizing the provider connectivity in a non-invasive way to support a provider’s decision and help drive an outcome with treatment-type messages is very important.

A practical example is messaging a provider with information on a particular product that he/she has selected to prescribe. For instance, safety/side effect info, reminders to check “dispense as written” if there is no available rated generic, or even an awareness message that the patient can be eligible for savings on the selected medication. The key in my opinion is to make sure the messages are non-invasive, support a providers decision and NEVER disruptive to work flow. Also, they should not be trying to change a provider’s behavior (i.e., “you are prescribing generic Lipitor but should be using Crestor”).

Patient-based treatment messaging is also a very effective tool. Supporting the patient with information regarding the products they are already on will only help compliance and persistence. Advertising to a patient should not be allowed unless the product is complementary to a current treatment regime. For example, a coupon for a laxative to overcome a side effect of a pain medication that they are currently taking.

Joe Meadows
Founder, Think Patients

I personally like the idea of information in my EMR being used to remind my physician to write a 90-day supply of a chronic medication I have been taking for several months, instead of a 30-day supply with refills. It saves me money and there is data that shows this exact use of EMR data has a positive return for brands that sponsor such a message. I also like the idea of my data being used to tell me about a copay assistance program that would save me money. And what about clinical trial recruitment? There is a current and growing shortage of patients for clinical trials in many therapeutic areas, and patients, providers and pharma will suffer if we can’t conduct those trials in a timely and cost-effective way. EMR data is an ideal place to look for these patients.

Joan Arata
Vice President, CareWave

EMRs present a new opportunity to reach physicians in the trusted environment of their actual workspace. CareWave, an outgrowth of MediScripts, is currently in several pilots of its new service that intends to change the way physicians work with and through their EMRs. The service would connect physicians to their peers, provide relevant clinical information and sponsored content in a completely new type of collaborative environment. It would be more than just traditional media-based promotion by providing the physicians with practice-based valuable resources.

Chris Dowd
Senior Vice President, Market and Product Development at PSKW

There are several reasons why pharma companies should be participating in the ongoing development and value-added benefit of EMR systems.

First, pharma can work with EMR systems to provide a triggered presentation of patient education sheets, advisories, compliance tips, disease management information, money-saving coupons, etc. Second, pharma EMR marketing can help providers meet Meaningful Use requirements. One of the 10 “Menu set” EMR capabilities that HCPs can use to prove meaningful use is “Send patient-specific education.” Pharma-provided education, as described above, can help meet this requirement. Third, pharma EMR marketing must comply with established guidelines. There is a growing framework of standards and safeguards that stipulate the times and places within EMR systems where promotional messages may appear, thus preventing undue influence. Finally, doctors must pay for their EMR systems and it’s not uncommon for systems to use pharma advertising to reduce the cost to HCPs.

Promotional Ads Have Their Place

Dowd was not the only one to point out the benefit to doctors of branded promotion in EMRs—no cost—as a couple of our respondents also see the opportunity for advertisements in the EMR space.

“Doctors are perfectly willing to consciously trade some ad space for a free EMR system,” says Leerom Segal, President & CEO of Klick Health. “What will provoke their ire is ‘back dooring’ promotional information without their consent. And their consent needs to be explicit, not buried in the terms and conditions of the site—do not forget the tweet chat that damaged Sermo’s relationship with its doctors.”

On the other hand, RJ Lewis, President & CEO of eHealthcare Solutions, sees the EMR space as open game for pharma promotion.

“The temptation to be at point of care, and point of decision making, is far too great for pharma to ‘respect the space,’ ” Lewis says. “As an industry, we’ve never been able to respect the sanctity of the physician’s office. Why would an EMR be any different? If anything, the intrusion by marketers (of all forms, not just pharma) will be far greater because of the data, and the ability to measure impact of promotion in such an environment. While I think it’s a noble thought, unless regulation forbids it, it will never happen.”

Meanwhile, even though Eric Pilkington, SVP, Digital Strategy at McCann Health, Torre Lazur Group, recognizes the benefits of being in the EHR space, he still recommends against advertising in it.

“Yes it’s true: Amazing amounts of personalized data can be lifted from EHRs and analyzed in an effort to better understand diseases and to service patients who suffer from them,” Pilkington says. “It’s also true that EHRs provide brands with the added opportunity to provide reference materials and tout savings and support programs to physicians who have prescribed their drugs.  But make no mistake about it: EHRs and ePrescribing applications are not additional outlets to market and advertise. For that, I’d suggest Medscape or Epocrates.”

What Doctors Want

The marketer’s opinion means nothing if it doesn’t match up with what physicians are looking for, but in this case they seem to be in sync. A poll of 31 U.S. General/Family Practice MDs, conducted for Panorama by MedLIVE from WorldOne Interactive, found that 48% of respondents would not want any kind of advertisements in EMRs, 26% would only tolerate branded pharmaceutical ads if it made EMRs free, 23% would like companies to provide additional non-branded educational materials or services, and only 3% would welcome any kind of advertisements in EMRs.

When asked to select the value-added services they would most welcome in EMRs, the majority (61%) wanted copay assistance program information, 52% would like additional information about the medication (e.g., drug-drug interactions, side effects, treatment guidelines, etc.), 42% like the idea of reminders about prescribing information that would be beneficial to patients (such as the 90-day vs. 30-day example that Joe Meadows mentions above), 32% think alerts that a patient is a good fit for a specific clinical trial would be helpful, while 23% don’t want any involvement from pharma in this space.

Steven R. Feldman, MD, PhD, Professor of Dermatology, Pathology & Public Health Sciences at the Wake Forest Baptist Medical Center and columnist for PM360, agrees with the 23% of physicians who don’t welcome pharma’s involvement.

“An EMR is a record of patients’ medical care and patients’ health records are their property,” Dr. Feldman says. “These records—whether paper or electronic—are not the place for the physician to put extraneous comments, and much less so a place for pharmaceutical companies to place advertisements or even educational material.”

Matthew Mintz, MD, FACP, Associate Professor of Medicine and Director, Primary Care Clerkship, at George Washington University School of Medicine in Washington, D.C., and also a PM360 columnist, sides with the other 77%.

“If pharma is looking to try to get into the EMR space, from a physician’s perspective, education and support (not promotion) should be the paradigm,” Dr. Mintz says. “Currently, if I am with a patient and need to research a clinical question or look for the latest guideline, I am on my own. Popular platforms like Up to Date are quite useful, but also pricey. I am sure that physicians would appreciate non-branded Up to Date like ‘buttons’ in the EMR at the point of care. However, once you start branding and marketing inside the patient’s chart, it starts feeling a little creepy. The EMR is the new patient chart and a documentation of the doctor-patient relationship. Branded advertisement does not belong here.”

Only 39% of our polled physicians agree with Dr. Mintz that there should be absolutely no pharma involvement in EHRs. However, 45% would be open to pharma providing more information to patients while 16% don’t have a problem with branded advertisements directed to patients. Physicians would want their patients to have access to the same additional information that they desire. Just over half think copay assistance program information would be the most beneficial to patients, followed by refill reminders (48%), educational materials about the drug they were prescribed (39%), alerts for clinical trials they qualify for (32%), and advertisements for a product that is complementary to a current treatment (29%). However, 19% think pharma should stay out of patients’ records entirely.

“There is a very fine line between what is considered promotional vs. value-added services for physicians within the context of EMRs,” says Gautam Gulati, MD, MBA, MPH, and Chief Medical & Innovation Officer, SVP Product Management at Physicians Interactive Holdings. “Education-focused promotions from pharma such as new drug safety alerts and value-added services such as eCoupon offers for patients are certainly acceptable in my physician point-of-view; and highly welcomed by our existing HCP users. The underlying characteristic of what makes these solutions acceptable is that they must ultimately enhance the quality of care.”


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