Diagnosing Digital MANAGING THE TRANSFORMATION OF HEALTHCARE COMMUNICATIONS

Transcription

1 Diagnosing Digital BY RACHELLE SPERO, EVP, DIGITAL MEDIA, COHN & WOLFE MANAGING THE TRANSFORMATION OF HEALTHCARE COMMUNICATIONS The role of digital and social media in healthcare marketing and communications is rapidly evolving. With the advent of self-publishing technologies and the expansion of mobile connectivity, digital channels have empowered millions of people to communicate around the globe within seconds. Healthcare providers, patients, caregivers, advocacy groups, pharmaceutical, biotech, and medical device companies have become increasingly active in emerging digital channels such as social networks, online communities, blogs, and various audio/video sharing sites. As two-way communication becomes the information vehicle of choice for these audiences, uncertainty looms about the participation of companies in these channels, as well as the regulatory, legal and business implications of such engagement. The roles of public relations, marketing, corporate communication, and public affairs are beginning to blur, causing a need to redefine each discipline s responsibilities and accountability in the digital age. The purpose of this paper is to provide healthcare companies with a framework for managing the transformation of healthcare by: Establishing guidance Defining the landscape Clarifying roles and responsibilities Addressing legal issues Understanding best practices FOR MORE INFORMATION: rachelle spero executive vice president of digital media p: rachelle.spero@cohnwolfe.com

2 Establishing Guidance Early adopters tend to own digital and social media and are usually the first to launch pilot programs that are based on trial and error. Successful companies work to develop a cross-functional digital media council that establishes one set of policies and standards that are based on innovative best practices and the law. In order to achieve consensus on policies and best practices, the first objective is to appoint a key representative from each discipline to be a member of the council. There should be at least one representative from regulatory, legal, safety, marketing, public relations, human resources and corporate communications involved in the council. The representative is usually a person who is passionate about the company and its products; knowledgeable about the company s internal culture, structure and politics; and is a senior executive. The purpose of the council is to evaluate current digital and social media policies, procedures, responsibilities and programming, with the end goal of identifying gaps and creating a plan of action that will evolve over time. Council meetings are usually the first opportunity for each department representative to learn what others are doing. More often than not, companies as a whole are doing more than they would have anticipated, be it internal (e.g. creating internal Wikis or social networks) or external (e.g. podcasting, building relationships with digital media influencers through media outreach, YouTube channels, etc.). Representatives of the council will also learn that there may be a number of areas overlap. For example, marketing, corporate communications and public relations are all conducting monitor audits to capture conversations online and there are multiple agencies conducting the same audits with different outcomes. Having a clear picture of what digital initiatives are taking place Defining the Landscape within the company can help shape the council s perspective on what policies and procedures need to be developed and where there are opportunities to be more efficient and save money. Finally, there should be agreement on the digital landscape so that when programs are presented to legal, there is consistency in how each communications and marketing discipline will work within U.S. Federal Drug Administration (FDA) regulatory guidelines. It s easy to become bewildered by the many terms used in the online world including: social media, digital media, Web 2.0, and/or social networking. It would be great if there was one term that could extend the current definition of online or interactive communications, such as new media. Here s a general example on how to bucket digital and social media. Digital Media Channels Social Media Applications [ 2 ]

3 Clarifying Roles & Responsibilities Digital and social media doesn t fit neatly into one discipline, and this has proven to be a roadblock for many companies. Is it PR/corporate communications, marketing, advertising, customer service or IT? In some organizations, everyone is doing it, and there is no integrated strategy. In other organizations, no one is doing it because of perceived legal ramifications or lack of clarity as to who is responsible. Additionally, many companies that are ready to get started still struggle with fundamental resource issues, such as sufficient head count to drive social media programs, the right kind of talent, and the appropriate role for agency partners. The council can help with reorganizing and aligning internal disciplines to implement digital and social media programs successfully. In general, public relations, corporate communications and public affairs professionals are responsible for building relationships with digital media influencers and may engage with influencers to correct inaccurate information, generate awareness, build community, increase thought leadership, prepare for a crisis, and/or communicate news that will result in earned media placements. Prior to engaging a digital influencer, most pharmaceutical companies understand they need to establish qualitative and quantitative metrics to determine influence. For example, a reporter such as Tara Parker-Pope with The New York Times is a journalist with the necessary credentials, and understanding the editorial process, she also meets the quantitative influencer metrics established by sites like the Healthcare 100. A qualitative influencer may be a key opinion leader in a specific disease category who has very little traffic, inbound/outbound links, or views to his or her site, but recognized by the industry as influential. Marketing professionals are creating content using social media applications for the purpose of brand and/or company communications, targeting and aggregating key audiences around a brand or disease awareness. This activity is usually done using unearned media and requires a greater level of Direct to Consumer (DTC) regulatory scrutiny. There are many areas where all disciplines collide. One of the most important is search. According to Forrester, 81 percent of the people going online for healthcare information are starting their experience at a search engine. Influencer sites often appear in the top organic search results of sites such as Google, Yahoo and Live Search and that is why it s important to be part of the editorial content. What s equally important is how your brand or company appears in the vertical search results on reference sites such as Wikipedia and WebMD. Tara Parker-Pope s Well Blog within the New York Times website. There are many ways public relations, corporate communications and marketing can collaborate by sharing search activities such as: Monthly rankings report Trends for all key phrases on the top search engines Search engine listing significant gains and losses Search engine optimization and marketing initiatives Keywords for messaging Multimedia press releases Social media tagging [ 3 ]

4 Addressing Legal Issues Understanding the official corporate digital and social media policies will help the review process for any new program. Below are several U.S. examples that guidance should address. Adverse Events The number one concern among pharmaceutical companies are the complexities involved with discovering adverse events (AEs) and reporting them to the FDA. There are many tools and methodologies for monitoring the digital channels, but about 90% of the time adverse events discovered online do not meet the FDA s criteria for a reportable adverse event, including: - An identifiable reporter - Identifiable patient - Identifiable drug - An identifiable adverse event The reality is most pharmaceutical companies are successfully monitoring for market intelligence, issues management and media relations purposes. Fair Balance The FDA has established clear guidance for DTC promotion and applying fair balance to marketing and advertising programs to ensure the public receives information about a drug s safety and efficacy profile and not off-label uses. It s important to remember that even non-branded activities could easily be perceived as branded by the FDA, especially if the drug is the only one on the market for a very specific treatment. Privacy AEs are often the first roadblocks to digital health initiatives, but privacy should actually be a bigger concern. Many PR and marketing professionals, as well as consumers, ignore the terms and conditions of a public Web site. More often than not, those terms clearly state manufacturers are not allowed to engage in community forums, chats or discussion boards. But what about monitoring? Consumer/patient privacy is less of an issue if the site is a public forum where members voluntarily provide their private information, but not on closed or password-protected sites. Trademark and Copyright Protection This is one of the most basic legal issues associated with online content, but it is often forgotten or unclear as to who owns consumer-generated media. The definition of what exactly Fair Use means is hotly debated and remains a poignant issue in a digital age where takedown notices and copyright infringement may discourage creativity. When using existing online content, there are several rules that companies must adhere to per Fair Use legislation and other copyright statutes. In the meantime, always remember trademarks and copyright on images, photos, music, and art must be licensed or pre-authorized by the owner. Transparency Practices designed to deceive people about the involvement of marketers via online communication calls into question the issue of transparency. This includes paying key opinion leaders or patient advocates to promote therapies online without disclosing that they have been asked to represent the company, using fake identities to impersonate consumers, anonymously posting information on blogs and message boards, disobeying rules established by individual communities, spam link-building, etc. Many marketers have attempted stealth marketing in the past and have been caught. Aspects of transparent communications include: - Clearly identifying who you represent - Being truthful and non-misleading - Responding based on factual data or an established point of view that is consistent with the products approved labeling [ 4 ]

5 Best Practices Pharmaceutical companies are actively engaging in healthy communications and marketing activities that include reaching out to digital media influencers and using social media applications. In fact, the FDA now recognizes the value of social media applications for sharing information quickly in times of crisis. The FDA s communication office, in collaboration with the Centers for Disease Control (CDC), created a blog to jointly address the peanut product recall. In addition, the FDA developed a widget so that consumers could syndicate news to their own sites. Finally, the FDA created a Twitter profile to keep consumers up-to-date on the Salmonella crisis. Pharmaceutical companies are also recognizing the value of social media applications such as RSS (Real Simple Syndication), tagging, mobile and Twitter. For example, AstraZeneca and Novartis have Twitter profiles, GSK includes tagging and syndication on its corporate site, and Bayer offers its corporate communications news in mobile format. A number of pharmaceutical companies are also increasingly warming up to the idea of sharing information with influential bloggers who are specifically associated with mainstream media publications. Approaching a blogger who is not part of a mainstream publishing company delivers less of a feeling of control for pharmaceutical companies since the blogger is not as likely to have an understanding of the legal issues associated with healthcare communications or any kind of an editorial filter. There are, however, more and more mainstream media reporters who are making their way to the blogosphere. This trend is only going to increase as the publishing industry continues to decline and layoffs increase as a result of the recession. There are many examples of influential health bloggers who were affected by the transformation of media including Ed Silverman, who made his mark on the pharmaceutical industry by sharing whistle blower stories submitted to his Pharmalot blog, formerly owned by The Star- Ledger of New Jersey. These independent influencers are credible and carry weight, and as a consequence, the public relations and corporate communications executive shouldn t rule them out just because they aren t employed by a mainstream publication. Instead, each influencer needs to be assessed on a case by case basis to determine if engagement is possible. [ 5 ]

6 Public relations and corporate communications professionals are also becoming more engaged in responding to inquiries from blog reporters and correcting inaccurate blog posts. The key to doing this most effectively is to focus on those blogs deemed to be the most influential and relevant to their disease category. Lilly, for instance, has been quite active in sharing product news with influential diabetes patient bloggers like Amy Tenderich of diabetesmine.com. In fact, the Diabetes Mine blog is no longer feared by pharmaceutical companies and everyone from Merck to GSK is advertising their diabetes treatments on her blog. Finally, some companies are venturing into the space in a more aggressive way and creating their own corporate communication(s) blogs. Johnson & Johnson has received a great deal of attention for JNJ BTW, a corporate blog in which there is talk about Johnson & Johnson what we are doing, how we are doing it and why. Mark Monseau, Director of JNJ corporate communications, spoke at the Health 2.0 conference about how J&J was able to deploy the blog by establishing policies for accepting and posting comments, addressing the rules about no product mentions on the blog, and by creating an accelerated internal process for issues management. Motivated by the success of its parent company s endeavor, J&J subsidiary Centocor has also begun its own corporate blog, nto411.com. Contrary to popular belief, J&J was not the first healthcare company to establish a blog. GSK s corporate communications in France actually launched a blog back in Since then, GSK has launched multiple digital and social media activities including an online community and blog to support consumers using its weight loss product, alli. In this case, the effort was lead by marketing and they were able to gain approval by demonstrating small success over many pilot programs. In addition, they established a process for monitoring and managing potential issues, such as adverse events, on the community forums. More and more pharmaceutical companies are creating groups in social networks for human resources and recruiting purposes, as well as for disease awareness and branding. For example, Merck created a cervical cancer group in Facebook, while AstraZeneca created a branded SYMBICORT channel on YouTube for asthma sufferers. Mainstream media has recognized that if you can t beat them, join them. For example, The New York Times has a presence in social networks such as YouTube, Facebook, and itunes. By working with The New York Times editorial within their social networking presence, pharmaceutical companies have a more controlled environment for engaging. An example would be reaching reporters on The New York Times channel on YouTube rather than posting video on YouTube alone. [ 6 ]

7 GETTING STARTED REVIEW: Establish a council to review current digital and social media policies, procedures, roles and programming. Identify gaps and create a plan of action to address the gaps. POLICY: Create standard operating procedures and policies to efficiently and legally monitor, engage and measure the digital channel activity in blogs, news sites, social networks, communities, search engines, hospital sites, clinic sites, association sites, forums, video/audio/image sites, comments, product reviews, etc.). ACCOUNTABILITY: Establish guidelines for organizing and reviewing digital and social media initiative across communications groups (PR, e-marketing, etc.) and define a common set of metrics based on business objectives, industry best practices and benchmarks. CROSS-TEAM WORKSHOP: Facilitate a cross-team workshop to walk key representatives from regulatory, legal, safety, marketing, and corporate relations through the various categories of digital and social media monitoring, engagement and measurement ensure there is consensus on policies and/or guidelines governing these activities. Conclusion While establishing policies and procedures is critical to the success of pharmaceutical companies moving forward, it is equally important for a council to meet on a regular basis (quarterly or bi-annually) to re-evaluate the current environment and determine if policy and procedure updates are needed. These ongoing meetings will also provide the council with the opportunity to review newly developed and implemented initiatives related to digital and social media communications. This allows all council members and their respective departments to be aware of what others in the company are doing. The continued participation by the council in managing the company s digital and social media policies and procedures will help ensure (1) that the company is on the pulse of the rapidly evolving digital and social media environment, and (2) potentially ahead of its competition regarding how it manages communications efforts in this space. About the AUTHOR Rachelle Spero is Executive Vice President of Digital Media for Cohn & Wolfe, New York. Rachelle has more than 16 years of healthcare public relations, interactive marketing and corporate communications experience from consulting clients such as GSK, Genentech, Merck, Lilly, Genzyme, Bayer and WebMD. Rachelle is a recognized expert in digital health communications. She has written standard operating procedures and policies for a number of global pharmaceutical companies and was recently invited to speak at the Consumer Health Conference as well as the PRSA conference on Leveraging Social Media in Health Care Public Relations. In 2008, her digital health programming for Januvia, Merck s first-in-class type 2 diabetes drug, won the Big Apple Award in the New Media category. At Cohn & Wolfe, Rachelle is responsible for collaborating with colleagues and clients on digital media strategies that generate brand awareness, establish thought leadership, define social media policy, build community for stakeholder alignment, and/or reach key constituencies in the digital channels such as blogs, online news sites, communities, social networks and mobile devices. Rachelle is currently the lead digital consultant for healthcare polices and procedures and provides digital and social media guidance to some of the largest pharmaceutical companies in the world. The CONTRIBUTORS I d like to thank Mike Presson, Vice President of Cohn & Wolfe Digital and Kristin Cahill, Senior Vice President of Cohn & Wolfe Healthcare, who assisted me with the original research, development and editing of this white paper. Special thanks to the healthcare professionals who provided advice and input along the way including Bill Martin, Cohn & Wolfe s President of Global Healthcare, Jill Dosik, Cohn & Wolfe s U.S. Healthcare Practice Leader and Stephanie Marchesi, President of Cohn & Wolfe New York. I d also like to thank my digital media colleagues for all their support including: Paul Walker, Eric Litchfield, Brooke Hovey, Steve Parker, Andrew Foote, Charlie Hart, Katie Greene, Bill Dixon, Ann Quattrochi and Francesco Paciocco. Finally, thank you to our client partners including: Genentech, Lilly, and GSK. [ 7 ]