Risk and failure are not always synonymous. But in the tightly restricted world of pharma marketing, coming up with the big ideas that not only engage, but also create experiences for consumers, can result in marketer self-restriction due to fear of failure. After all, it’s tough to walk through a regulatory minefield and not feel a little nervous. But it can be done.
In partnership with Cannes Lions Health—founders of the annual, highly anticipated festival (June 18-19, 2016) celebrating excellence, creativity, and innovation in two categories, Pharma and Health & Wellness—PM360 presents an exclusive Circle of Excellence, delving into the insights of both Cannes Lions Health Jurors and industry thought leaders about risk, creativity, and how to balance these to create cutting edge campaigns, fearlessly. We asked:
- In terms of regulatory restrictions on pharmaceutical marketing, what are the biggest risks that keep marketers up at night?
- What have you done/or seen that allows marketing to rise above or move around regulatory risks to boost creativity of campaigns while remaining compliant?
- In terms of pushing the boundaries, what do you see as the best/most successful examples that have achieved this balance?
- What emerging/changing regulatory risks do you see that could further impact pharmaceutical marketing and the need for greater creativity? How can marketers prepare for this? What role will technology play in mitigating risks?
- What effect does this fear of risk have on campaigns—and how can pharma marketers push past the fear to create disruptive, innovative and compelling campaigns?
- What are the rewards to those who do manage to balance all these elements?
The regulatory environment in pharmaceuticals is really unlike any other field. As an industry we must chart our own course. The majority of regulatory problems occur when we start to talk about and force-fit brands into solutions around diseases—if we only spoke about the disease we would never even have the need for lawyers!
That said, health and wellness/pharma brands need to go beyond traditional or even digital creative campaigns to unite the practical with the fantastical and deliver on promises of better health outcomes for patients. This means frictionless patient/HCP customer experiences (CX) across all channels, with mobile as the centerpiece of a unified data-driven program.
So let’s expand this idea and tie together both ends of this communication continuum. From the digital side, a future awaits in which data-informed creativity leverages patient/HCP digital habits to create a more contextual and personalized “health on demand” experience. At the other end are opportunities to tap into important moments of patient/HCP interactions—and by doing so pharma marketing could avoid much regulatory quicksand.
How do we bring these two arrowheads together?
Brands can start by diagnosing high- and low-friction points in both the virtual and physical worlds throughout moments of interaction: How does a customer navigate through an app? How is the treatment decision made? How long is an interaction on brand.com? What are the disease-state search queries? And when/where is there a desire for information and treatment? Through this deconstruction, a brand is enabled to create the ultimate experience solution.
Experience is the new brand—and patient-centeredness is at the core of the patient experience. Brands must leverage decision points to build upon their offerings. And this should be no different from how a frictionless CX would extend and interact with HCPs. This is the promise of a “borderless” experience—one that bolsters health outcomes and uncovers new opportunities for brands. If creativity is the process of magically connecting things in awe-inspiring ways, what could be more creative than connecting patients and HCPs with life-changing experiences!
The future of healthcare clearly belongs to personalized health solutions. Companies that have digital health and analytics capabilities will have an edge over traditional drug and device companies. Regulations that stop pharma companies from accessing patient data and directly engaging with them will prove to be limiting—and have a severe impact on the way companies connect with patients and market their brands.
Pharma marketers have so far remained doctor-focused and communication has largely remained disease and medicine centric, with emphasis on multi-centric trials and evidence. To create compelling campaigns, marketers have to let go of the fear of going to the patient or talking about patient stories and real patient experiences.
Knowing the Regulations
Personalized care, a more meaningful engagement with doctors and patients, real-time responsiveness and data use for decision making will be the drivers for marketing strategies—marketing teams and creative agencies must be equipped to manage changing customer expectations. This means having the ability to understand regulations and then knowing how to operate within the framework, instead of completely avoiding taking risks for fear of regulations.
Category leadership will be attained by brands that can create disruptive and innovative campaigns that help bring about behavior change. It is not merely about brand differentiation, but adding value to the patient’s life. Brands can achieve this by partnering in early diagnosis, disease management, patient support, and improving adherence. These are all challenges that need creative solutions. Agencies that dig deeper will surely be successful in creating compelling campaigns.
Today, a digitally enabled patient has more access to information about his condition, his own health data and the choices he has available. The patient is becoming less dependent on the doctor—and even to a lesser extent on the pharma companies, which were previously the custodians of disease pathways and management information.
In such a digitally enabled world, pharma companies must compete with the likes of Apple, Samsung, and IBM for patient engagement. This means building capabilities beyond just medicines and being accountable for outcomes. They have to be a part of the patient’s world, listen to their stories, and empathize with them.
Not all the boundaries pharma marketers are facing are real! In fact, we mostly create our own black boxes. In digital innovation, which is my focus, we find that a lot of these activities are far beyond traditional pharma marketing. In terms of digital, the role of patients is so important that it is no longer possible to avoid dealing with them.
Education and early involvement is the key. I believe these are the two major keys when it comes to the success of innovative ideas in pharma. But legal and regulatory teams need to feel comfortable enough to get the new technologies cleared. At the same time we need to realize that it is a step-wise approach. We can’t be Google in one day—but do we need to be Google? Onboarding teams that realize the value and understand the impact of innovation will get everyone working to get a project cleared in the most ethical and compliant way.
The Rewards of Risk Taking
In very competitive market, traditional marketing is not differentiating brands anymore. The need to find innovative approaches, including digital, is increasing every day. And in this social media driven world, gaining the connections with customers is a key.
Those willing to take the risk and pass through these barriers will not only gain business benefits, but will also play a big role in changing the industry. We see that on a daily basis. Once one company creates something, all other competitors go in the same direction.
So, while we don’t need to be Google, we need to work with them! We can’t master everything—we need to partner. We also must change our style to become more agile and disruptive. Partnering with the tech/innovation industries and supporting startups will create a new role for pharma companies, more like an innovation incubator/accelerator, which will give pharma new access. The tech industry needs pharma for our insights and knowledge—and we need them because they have the needed technology. With such synergy, the impact on the community will be great.
Medical information provided by artificial intelligence (AI) is one example of technology that pharma companies should embrace, but to date they have been reluctant to do so. In a highly connected world in which digital users, including healthcare professionals, demand easy and quick access to information, AI represents a huge opportunity to offer an engaging and versatile communication alternative to users. However, because of remaining concerns around the user-interface, pharma companies still consider AI unrealistic.
One of the things we have done is to utilize a smartphone app, LINE, which offers a simple and convenient messaging service. Through this SNS, we provide medical information—sending messages on upcoming webinars, new website content—and a variety of new services that support the daily clinical practice of HCPs. Several services use an interactive auto-response functionality, which provides an easy, practical and innovative experience. Alert messages, for example, about the level of asthma risk factors—pollen, flu, and yellow sand are sent based on the user’s smartphone location.
AI and Compliance
The biggest hurdle lies in ensuring that automated text responses are operated in a fully compliant manner. In order to operate different communication streams within each service consistently, we must ensure that all automated responses are pre-approved without exception, and that the technology is fully tested before service release. Each time a subscribed HCP starts using a service, a signal is sent to detect which service is designated to handle the input messages.
For instance, if the medical dictionary menu is specified, the relevant engine is detected to handle the input message. However, if the user input text messages are irrelevant or inappropriate to the specific service, the user is informed and automatically navigated to our medical call center. To handle adverse-event related input messages, all the messages are monitored twice a day. All inserted messages are scanned, and reported to the relevant department, if necessary, to ensure that the appropriate measure is taken.
Boosting creativity while remaining compliant can be challenging in our industry—but, at all times, acting with the highest level of ethical standards is the utmost priority.
The Australian pharmaceutical industry is deeply indoctrinated by the regulatory climate. It breeds ubiquitous fear in the face of potentially life-changing campaigns. We know disruptive and innovative ideas can change behavior—and jolt doctors and patients from complacency to positive action. But even the most innovative and disruptive ideas can get paralyzed if the right stakeholders aren’t included in the creative evolution process.
Our business is to help clients shift the focus from fear to progress. We understand the importance of adhering to the various codes. But how can we affect change beyond the code? To help answer this question, our dedicated creative teams’ sole responsibility is to tap into a thought process that transcends the pharmaceutical environment. They are encouraged to vacate the healthcare world and take an entirely different perspective. This is our formula for testing the boundaries of our regulatory confines to achieve disruptive ideas that nudge human behavior.
In the past, many clients approached us asking for disruptive campaigns involving a multichannel digital strategy or a campaign platform that “holds everything together.” Then, at the last minute, they get cold feet. The common thread in these stories: A lack of stakeholder engagement and true field insights that drive a targeted need for behavior change. These lessons compelled us to change. Today, we invite clients to participate in the creative development process from the start. This helps to strengthen ideas, get clients more invested from the beginning—and ultimately helps them overcome the regulatory fear factor.
Start With a Future Vision
We work similarly to a multi-disciplinary care team in a hospital and are indirectly dealing with human lives—so we don’t like to make assumptions about doctor and patient journeys. We start with a future vision of health and then work backwards to a prototype. Through a series of pilot testing phases, we involve key stakeholders—developers, clients, and doctors—and guide them through every development stage all the way to the place where functionality meets design.
This process enables us to reach the tipping point of innovation—and sharing it with clients is what dissolves the perception of fear and replaces it with the confidence they need to bring disruptive, innovative campaigns to life.
It takes a village to push past regulatory risks and create innovative campaigns. First, you need “A” creative teams that are experienced and undaunted by the challenge of ideating alternate ways to express the brand benefits within the regulatory boundaries. In addition to that, a trusted partnership with your internal account team, client, and regulatory department is integral. You need people on your side who are open and excited about partnering together to solve problems. I have found that when all of those stars align, we succeed in delivering great creative that is still compliant from a regulatory standpoint.
Also, if regulatory risks get in the way of “what” you can say in regard to features, you can focus your brand promise and messaging on the “why” instead. If people understand why they need your brand, they will automatically buy into what the brand offers—and that allows you to move beyond some of the things that hold you back from a regulatory standpoint. Lastly, what you can’t always say with words, you may be able to say with visuals. There have been many times that we have relied heavily on a brand visual to express a brand story because regulatory risks held us back.
How to Hit the Mark
Authenticity is more important than ever today as there is a halo of distrust due, in part, to regulatory restrictions. From a patient campaign perspective, I think the Allergan’s Viberzi campaign for Irritable Bowel Syndrome does a great job to de-stigmatize the condition through honesty and humor. While IBS is not a laughing matter for those who suffer from it, you won’t succeed in getting patients to understand what your brand offers if they are afraid to broach the subject with their doctor.
Humor, in this instance, succeeds in bringing IBS out in the open so that people can be more comfortable about seeking help. The brand campaign delivers on authenticity by showing that it can relate to the patient’s underlying feelings about the condition—and that can help patients move past the inherent distrust by making the brand appear more human and relatable.
I’m not sure if the following keeps marketers up at night when it comes to regulatory restrictions, but it certainly keeps me up. What keeps me up is a nightmare that I call, “the ridiculous spiral.”
The ridiculous spiral happens when an idea is raised that could lead to positive, compliant programs. Then a voice says, “Well what if someone misinterprets your intention to do XYZ as a way to get around a specific regulation.” Then another voice chimes in and says, “Yes, and if someone can interpret the program in that fashion, then you can’t do ABC either.” And then the next voice says, “Hmmm, remember program MNO that we approved six months ago? If XYZ could be misinterpreted and ABC could be a possible off-shoot of XYZ, then MNO could be interpreted as an interpretation of an interpretation of an interpretation—so you need to pull that program.”
Finally, the person who came up with the initial idea stands there perplexed and concludes, “No good deed goes unpunished—so I will stop raising good ideas.”
Working with Regulatory Boundaries
Boundaries should not be pushed. Most regulatory boundaries are pretty black and white. I recommend that you redefine the boundary that you are facing by introducing a solid medical or patient-focused rationale.
So, how can our industry’s marketers push past fear to create innovative and compelling campaigns and programs? The best way: Put yourself in the shoes of your audience. When you see your brand fully through their eyes, you will begin to see possibilities that are compliant, unique/differentiating, and in some cases, disruptive.
Laws and regulations lag behind technology and innovation, when it comes to promotional marketing. So I tell our teams to let the ideas run free—we can reel them in subsequently. The FDA is very consistent regarding their direction that the message—not the medium—is what matters. There is room for interpretation and I’ve been successful partnering closely with clients and legal/regulatory teams to share precedence and prepare stimuli for discussion with OPDP. Our clients can always ask for advisory guidance. This may take time but it can provide a path past the risk concerns and paralysis we sometimes face.
But in terms of emerging risks, I’m curious about the new study the FDA has commissioned regarding the use of animation in DTC marketing. Research is underway to assess whether or not the use of animation or animated characters interfere with a patient’s processing of risk/benefit claims. I’m a huge proponent of consumer education and countless studies suggest that individuals learn through different methods and repetitive exposure. We use creative approaches to educate because they work. Restrictions on creativity like this followed by AMA’s call for a ban on DTC advertising may ultimately impact the way we market Rx products to consumers. In a world of healthcare that is increasingly complex to navigate, creative solutions should be embraced, rather than restricted, to deliver effective and efficient education healthcare agencies are well equipped to deliver.
Embrace Emerging Technologies
Finally, I submit, “We have nothing to fear but fear itself,” as we continue to push the healthcare industry to embrace emerging technologies. Test, learn, and create precedence. As agency leaders we have a responsibility to push communications to advance along with the scientific and technological advancements made by our clients year after year. We all have heart for creative momentum and social experimentation—let’s remain steadfast in this direction and keep in mind that empowerment lies in knowing the truth. Balancing risk with creativity leads to informed customers and results in loyalty for brands and manufacturers.