Executive Summary
This report
captures the perspectives, insights and discussion presented by
industry leaders at a recent conference organized by the Center
for Business Intelligence on “Marketing and Supporting
Pharmaceuticals over the Internet? (January 27-28, 2000). 15:00 2000/10/1315:00 2000/10/13Each
chapter is an edited transcript with additional commentary and
analysis included.
Chapter
3 starts out this report by describing the Internet as a
medium that commands perhaps a disproportionate amount of trust
from its readership. About half of web users (49-55%) view the
Internet as a reliable source of health information, versus only
25-30% for newspapers and 13-28% for television. The reality is
that the Internet is largely a self-regulated medium, and as such
the information it contains is often misleading. The author, John
Mack, suggests that the pharmaceutical industry must take the high
road to help consumers find credible and balanced health
information, thereby adding more value and credibility to their
own marketing initiatives, and preventing tighter government
regulation of the pharmaceutical Internet presence. To do this,
one must build trust with the consumer by adhering to principles
if quality of information, ethics and privacy. Mack describes
efforts by several organizations charged with setting the
standards for quality, ethics and privacy, including The Internet
Healthcare Coalition, the Hi-Ethics Alliance, The Alliance for
Online Privacy, as well as government guidelines from the FTC and
the Department of Health and Human Services
In Chapter
4, Marc Scheineson examines the appropriate use of the
Internet by drug and biologics manufacturers, and the FDA's
enforcement posture. Pharmaceutical companies have been given the
go ahead for Direct-to-Consumer advertising, breaking down
traditional consumer protection provided by learned
intermediaries. According to the FDA, consumer protection can be
assured if all media, including the Internet, abide by the rules
of accuracy and fair balance. Any positive claims must be
accompanied by negative information such as side effects and
contraindications. This is a simple principle, yet the interactive
qualities of the Internet raise some ambiguity as to how fair
balance is interpreted. Scheineson warns the reader that it is
their competitors that hold the regulatory leash. Most warning
letters have been generated not by FDA surveillance, but by
competitor complaints.
While the FDA
has stepped back from redefining its regulatory role over
manufacturers using the Internet for promotion, the agency is
seeking greater regulatory power over on-line pharmacies.
Scheineson discusses the inclination of the FDA toward regulating
non-manufacturers on content, and the legal (constitutional)
implications of such a move. The author describes other government
organizations that are seeking to exert their influence or control
over the medium, especially with regard to maintaining consumer
privacy, and the likely impact that will have.
The discussion
extends to international issues and how differences in laws and
market approvals add several more layers of complexity. The
Internet is an international medium, accessible by anyone, yet
what is allowed for promotion in one country may be prohibited in
another. Scheineson describes stopgap measures for staying within
the margins of appropriate use for multiple countries. The author
describes numerous intentional harmonization conferences directed
at making the rules consistent for a medium that knows no
boundaries.
Another
perspective on the regulatory issue is offered by Peter Reichertz
in Chapter 5
Reichertz describes the implications of the Washington Legal
Foundation vs. Henney case and its First Amendment considerations.
Whereas the FDA sought to extend greater control over what
physicians and consumers can receive and communicate in terms of
unapproved indications for a drug, the Internet is a medium that
is nearly impossible to control. Some would argue that the
Internet should have a greater degree of First Amendment
protection because, like a library, it is a repository of
information that is actively sought by the user. Reichertz
describes the current status of other national and international
government agencies that are trying to define their jurisdictional
reach, including the FTC and the European Commission. To give the
reader a comprehensive picture of the FDA position on marketing
over the Internet, the author discusses recent civil actions,
classified as Warning Letters or Notices of Violation for:
-
Promoting
unapproved uses
-
Lack of
fair balance
-
Comparative
claims
-
Promotion
of drugs and devices approved in foreign countries, but not in
the US
-
Referring
to public information or links to web sites discussing
unapproved indications
-
False
and misleading information
Creating a new
web presence from nothing and entering into an increasingly
crowded dotcom environment can be a high-risk business strategy.
In Chapter 6,
David Heck and Dan MacDonald present the rationale for an
alternative strategy: partner with established Internet players
who have already put in the investment and have built a
substantial customer base. Strategic alliances can be arranged
with publishers, medical societies, patient advocacy groups and
healthcare portals to allow pharmaceutical companies to gain
access to an existing pool of interested consumers. The enormous
amount of traffic going through healthcare portals presents many
opportunities for direct-to-consumer promotion, patient education
and patient recruitment for clinical trials. Some companies, such
as the authors? CenterWatch, help pharmaceutical companies
expand connections with these portals and other key web locations,
to redirect Internet users for a particular purpose. A CenterWatch
deal creates a winning situation for both sides. The consumers
gain easy access to research news and clinical trial opportunities
relevant to their own medical conditions and the pharmaceutical
companies gain access to truly interested and self-driven
consumers. Use of the Internet can significantly cut costs in
patient recruitment, as described in this chapter, as well as in
advertising and sales detailing, as described in other chapters of
this report.
Truly
integrated off-line and on-line marketing campaigns for
pharmaceutical brands are actually quite rare. However, most
companies recognize that integrated campaigns have distinctly
higher response rates. In Chapter
7, Drew Neisser explains the rationale for integration,
ways to measure the results, common reasons for failure, and
outlines a strategic approach to integration using examples from
successful integrated marketing campaigns. Integration does not
mean developing a print ad and putting it on-line. That is
re-purposing in the bad sense of the word, dooming integration to
a creative afterthought. Too often, marketers are be simply
looking at different media as separate ways of delivering a
message and end up trying to maximize the effectiveness of each
medium separately. Neisser presents creative ways in which
on-line, print, and broadcast media can be closely linked and
mutually supportive, while maintaining consistency in the message.
AstraZeneca
has taken the innovative step of creating the position of
Electronic Promotion Manager assigned to specific therapeutic
areas. The EPM combines expertise in information technology and
marketing and operates as part of a cross-functional team. Michael
Cord, EPM for the gastrointestinal team, describes in Chapter
8 how a pharmaceutical company can use the Internet to
increase brand awareness and credibility and provides many
insights into big pharma integrated marketing strategy. This is
illustrated with several examples from AstraZeneca's promotional
campaign for Prilosec.
Although many
may argue as to the current impact of on-line advertising, there
is one established fact that strongly supports the use of the new
medium: merging the disciplines of interactive marketing with
direct marketing and traditional advertising makes a company's
marketing communications investment work harder, improves
accountability and enhances brand value. Studies conducted by the
US Department of Commerce indicated that direct marketing is twice
as effective if combined with Internet marketing. In Chapter
9, Philip Odoom provides us with a contrast between the
“old? style integrated marketing and the new synchronized
marketing on the Internet. Specifically, he describes the
technology and logistics behind direct response marketing, a
method tailored for the Internet and used to track and adapt
promotional campaign progress in real-time. Unlike traditional
advertising, response-oriented advertising does not try to
understand why people behave in a certain way. It simply measures
their actual behavior, and changes the advertising mix to maximize
the response. According to Odoom, this new era of marketing will
require a cross-discipline management approach, not dominated by
any one medium.
A wealth of
information has made it increasingly difficult, if not impossible,
for physicians to stay current on medical developments and
pharmaceutical product information. At the same time, it is
becoming increasingly difficult for pharmaceutical sales reps to
gain access to physicians, and to provide them with the
information that they need. Heavy patient loads and limitations
set by managed care have left only a few minutes for the message
to be delivered. In Chapter
10, Don Paullin introduces us to a solution ?
e-detailing. This new method involves the development of web-based
interactive presentations that provide the physician with the
required information, and the opportunity to set an appointment
with a sales rep if so desired. Presentations are brief, and
available 24 hours a day, 7 days a week. With e-detailing,
physicians can now access detailed product information at their
convenience. Advantages include a higher response rate than
traditional detailing, access to physicians who otherwise would
never set aside time for a sales rep and the ability to extend the
reach of smaller sales forces.
In Chapter
11, Steve Schack and Tom Grondalski explain how
pharmaceutical companies can build or gain access to electronic
communities of patients, healthcare providers, payers and drug
purchasing groups. The terms B2B (business-to-business) and B2C
(business-to-consumer) take on specific meanings from the
pharmaceutical industry. The authors describe how an increasing
emphasis on direct-to-consumer advertising (a B2C endeavor) and
greater access to healthcare information on the Internet is
empowering the patient. Remarkably, the authors note, this trend
will erode the physician's and the provider organization's
role as privileged gatekeeper to the patient's healthcare. This
will result in providers becoming more consumer-focused, a welcome
change for many who are frustrated with today's bottom line
approach to treatment. The expected exponential growth in B2C
e-commerce will include disease therapeutic sites designed by
providers to help patients manage their condition, as well as
online drugstores and healthcare product vendors that cater
directly to the empowered patient. E-commerce will work for the
pharmaceutical companies on the B2B side by streamlining the
supply chain, increasing the reach of the sales organization with
e-detailing, and even providing direct contact with regulatory
agencies such as the FDA. Schack and Grondalski outline the
various applications of the Internet that extend along the entire
product life cycle, and how they are designed to suit the needs of
the various stakeholders in a pharmaceutical company's business
network.
The old adage
says that if you build a better mousetrap, the world will beat a
path to your door, but in the Internet world of millions of
“better mousetraps? it is extremely difficult to get noticed
and even harder to pull in a significant amount of traffic. In Chapter 12, Ian Cross explains the steps required to gain
access to a large volume of web site visitors, and provides a
breakdown of the various tools of the trade such as banners,
direct e-mail, e-mail newsletters and rich media. Once the
customer is re-directed to the company's web site or partner
portal, customer retention costs become significantly lower than
for traditional media. If one can obtain customers by, for
instance, developing a wellness program, it is relatively easy and
cheap to keep in touch through monthly newsletters, or other means
over the Internet.
In Chapter
13, Michael Sklanowsky explains how to get near the top of
the list when consumers conduct search engine queries related to
your company's products or services. This may be a deceptively
trivial issue, but it is not. The vast majority of Internet users
use the Search Engines to identify web sites related to their
interests. A company may have research or products that are
perfectly relevant to those interests, but never show up in a
query because the result is too far down the list to be noticed.
Judicious use of keywords and registration of web sites will
guarantee improved visibility, and capture of a larger portion of
the 70 million healthcare information seekers on the Internet.
Douglas
McCormick discusses the problem of user verification in Chapter
14, an issue of critical importance to enabling advanced
services and marketing over the Internet. Once a web page or
service is placed on the Internet, it immediately becomes
accessible to a global audience. Any promotion becomes a
direct-to-consumer promotion. Any claim for an approved indication
becomes a claim for an unapproved indication in a different
country. Information meant for the discerning eye of the physician
becomes fodder for the public, the press and the investor market.
McCormick outlines five main approaches to qualifying audiences
on-line, including the pros, cons and costs, an demonstrates how
audience verification can help a company:
-
Ensure (to
varying degrees of security) that the right information gets
to the right reader
-
Protect
itself from liability due to inadvertent legal and regulatory
transgressions
-
Maintain
more accurate profiles on key user segments
According to
Bob Greene, the key to evaluating return on investment (ROI) on
web advertising is to first determine your objective. He describes
in Chapter 15, how the campaign is plotted out in
stages, with benchmarks established against which one measures
success. The benchmarks can be impressions, hits, registrations,
requests for samples, or requests for prescriptions. Many of the
Internet-specific measurements, such as click throughs and
impressions, provide hard numbers, but are not always clearly
linked to revenue. To obtain objective comparisons of a
campaign's success, return on investment has to be tied to these
measurable goals. As the interactivity components of advertising
on the Internet grow, clearer measures of their revenue-generating
potential will become available. The industry is trying to reach a
consensus on a standard measurement. Organizations, such as FAST
(Future of Advertising Stakeholders) and the Internet Advertising
Bureau are attempting to have the industry voluntarily come
together and agree on what is important, what should be measured,
and how it is reported.
A second
perspective on ROI is offered by Anthony Schneider in Chapter
16. The author discusses advertising tools that permit
measurements of success. These include banners with
point-of-purchase capability, games, video, rich media or
e-commerce banners that, without building a back-end e-commerce
web site, are able to advertise, engage, and offer e-commerce
functionality. The advertising investment landscape is changing on
the Internet, the author explains. Cost Per Thousand (CPM), a
measurement that determines the cost of interactive advertising,
is going down. At the same time the number of sites that accept
banner ads is at least doubling every year. A new model,
payment-by-response, is growing in prevalence, representing a
model of payment that cannot be rivaled by any other media.
Schneider discusses the utility of other advertising vehicles
including e-mail, permission marketing, coupons, web partnerships,
affiliate programs, advertorials, interstitials and sub-sites,
providing the reader with a panoramic view of the marketing tools
that cut the cost of reaching new customers. But reaching
customers is only half the equation for ROI. The author goes on to
describe the advantages of extranets and B2B e-commerce for
disintermediating and increasing supply chain efficiencies. In the
final analysis, however, Schneider emphasizes that return on
investment has more to do with seizing opportunity than directly
linking to an increase in revenue
Whereas an
Internet presence comes with many of the same regulatory concerns
as developing any other promotional material, this unique medium
has many capabilities to which conventional models of regulation
may not map. The Internet model of a world in which patients,
healthcare professionals and pharmaceutical manufacturers converge
has many layers of regulatory considerations. Michael Pozsgai
peels back the layers in Chapter 17 to reveal each
issue that bears upon e-commerce content, design and strategy. The
first layer is to determine for whom the promotional vehicle is
intended. Is it for patients, journalists, investors, or even for
prospective employees? Another layer: is the information specific
to a particular country, and will it abide by the laws and
regulations of that country? Are there appropriate disclaimers or
disclosures for other countries that may be able to access it?
Another layer: is it a promotional piece? Direct to consumer
promotion is illegal almost everywhere except the US. Another
layer: is the content discussing efficacy claims for products that
are approved in one country, but not in another. And the list goes
on. Poszgai tells us that the more successful web sites tend to be
distinctive by providing a higher level of service to the
customer. In this context, a company may insulate itself from some
of the regulatory pitfalls by providing non-promotional on-line
resources such as continuing medical education, international
scientific symposia, peer-to-peer physician communication and
possibly adverse event reporting.
The web's
global reach and explosive growth present both opportunity and
challenge. Non-English access is the fastest growing segment of
the Internet, and a global industry must implement a strategy to
improve consistency between print and on-line communications
across languages, adhere to international differences in
regulatory law, and maintain cultural sensitivity. Simply
translating from one language to another, without considering
these differences, exposes a company to significant risk. In Chapter
18, Philip Onigman details a language strategy that
follows these criteria while saving costs in advertising design
and development. Interestingly, a language strategy is not only
used to extend marketing internationally, but it is also used to
gain greater access to domestic language markets. The important
language will be the one in which the client understands the
content of your message. The author also outlines a technological
approach using a central repository database of language and image
content to ensure consistency and alignment worldwide.
Where are the
most promising international markets? Chris Davis provides us with
some answers in Chapter 17, along with statistics
that suggest enormous opportunities are in the offing for
companies that are prepared to let go of their English-centric
strategy. Currently, US-based content and e-health services
dominate the landscape, yet international healthcare markets
present a vast, untapped online marketing potential for
pharmaceutical companies.
Davis informs
us of statistics that show on-line access rates for countries such
as Germany and China are set to explode. In Germany, expansion
will be propelled by a concerted government effort to provide 40%
of the population with Internet access by 2005. In China, Internet
usage tripled in 1999 to about 7 million people. Data from
European Community and Asian markets testify to the same
phenomenon. We are only now seeing the beginning of a
supernova? of Internet growth in worldwide markets.
1. Executive Summary
2. Introduction
3. Improving the Quality of Health Information on the Net to Increase Value and Educate Consumers
3.1 Introduction
3.2 Building Trust on
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