Regulatory and brand compliance risks of social media marketing are well known and have dominated headlines for some time. Although not as sexy, PowerPoint presentations used for pharmaceutical sales and marketing purposes, like Speakers Bureaus, also need to be managed to ensure compliance and avoid exposing a brand to increased regulatory scrutiny and even fines. Companies spend millions of dollars on risk management technology, but when it comes to these presentations, many have very limited processes in place to manage them, even leaving speakers to create their own decks, often at the last minute with old data and branding. How can pharmaceutical brands ensure regulatory and brand compliance to mitigate risks and reduce fines without creating complex processes that are sure to frustrate users?
It’s like balancing a three legged stool, where the legs are 1) the Brand, 2) Regulatory Compliance and 3) the Speakers. The Brand team needs to ensure that the content and data presented are accurate and relevant and that it will resonate with their target audience. The Compliance Officer must ensure that the content presented meets FDA, CFA and/or DEA requirements and that the Brand does not release anything without Regulatory approval. And finally, the Speaker—who may be a scientific liaison, healthcare provider and/or sales representative—just wants an easy way to make a polished and informative presentation to his peers. The last thing a speaker has time for, is fumbling around with PowerPoint.
There are several points in the lifecycle of a presentation where you can control risk: Content creation, personnel and permissions, distribution and auditing. You can implement controls at any of these points.
1. Content Creation
The presentation is typically a collaboration between medical experts and design experts. It is then routed through regulatory. Most big pharma brands have dedicated personnel and put processes in place to manage that workflow. However after approval, better organization of the slides will reduce risk, as it lets the Brand distribute the right versions, to the right groups, and then makes it easier for the Speaker to find the right content for his/her presentation purposes.
So, don’t just upload a master deck into a network or Dropbox folder. Cut the master deck into smaller modules or chapters. Start with a core presentation: A high-level overview of the drug, which covers the required information everyone must know. Then, create modules or short chapters that expand on the core. For example, the modules could delve deeper into clinical studies, disease states, side effects or drug administration information. The idea is to present the chapters in a hierarchy, with obvious file names, to make it easy for the Speaker to find the right slides, in the correct order, for his/her presentation purpose.
2. Personnel and Permissions
Most pharma organizations already have medical, design and regulatory experts ensuring that the final presentation meets those requirements. Take that process to the next level, and designate roles for distribution, which gives more attention and importance to permissions. Don’t treat permissions as an afterthought. Use a content management system (CMS) to automate the process and garner better control over who accesses which content, which will provide an added level of security and risk management.
Given the sensitive nature of the content within Speaker presentations, merely uploading to a shared drive or emailing it will leave the company open to risk. Even with the variety of content management solutions available, a rep often emails the master deck to the speaker at the last minute—because it’s just easier for them at that moment. The risk is that once the speaker has an emailed deck, the company has no idea what slides he is presenting, in what order, and whether or not he is even using current content. Once it’s gone, it’s gone.
But, a good CMS will control the distribution without adding to everyone’s workload. It will make it easier. It should include a presentation wizard in which speakers can select their modules and customize their presentation for their meeting. And, it should force out new information, so the brand doesn’t have to worry about speakers using old material. Last, it should have a presentation mode, whereby the Speaker can give his/her presentation from the system, without having to download the content. This way, it always remains in corporate control—meeting compliance requirements—and it provides a log of the meeting
4. Feedback and Reporting
Some refer to this as closed-loop marketing. Usage and feedback gets sent back to the brand team, where they then modify the content based on speakers’ comments, and then, put it out for distribution and use again. It’s a cycle. Systemic tracking and reporting tools to audit which slides/presentations are presented by whom, to whom, when and where provides the brand and regulatory with a precise record of activity. Adding comments features will allow the speakers to communicate directly to the brand about specific content (slide, presentation, PI, etc.), spontaneously, in real time. This is more efficient than waiting for someone to write up an email, which they probably won’t get around to doing, or waiting for the next conference.
Finally, make it easy. If the solution is too complicated, no one will follow it, and your company will still be open to risk. It needs to be easy for both the administrators on the brand and regulatory side, and for the speakers in the field. The modules should be presented in a clean, logical flow. And the CMS, if you choose to use one, should be a clean, intuitive application, with minimal, if any, training needed. In the end, simplicity will win.