Healthy Skepticism Library item: 15292

Warning: This library includes all items relevant to health product marketing that we are aware of regardless of quality. Often we do not agree with all or part of the contents.

Publication type: news

Gray S.
The internet marketing code
Pharmafocus 2009 Mar 17
http://www.pharmafocus.com/cda/focusH/1,2109,22-0-0-0-focus_feature_detail-0-492599,00.html

Full text:

Virtual and online sites could offer pharma a new communication channel, but raise many questions on compliance, says Steven Gray

Compliance officers in the pharmaceutical industry don’t live in the real world – everyone tells me that! They are removed from the pressures of everyday business and don’t have to deliver against sales targets. Instead, they seem to live in an alternative universe where they expect every marketing campaign to be 100% compliant the first time it enters the copy approval system.

On the other hand, marketers don’t exactly live in the real world either – I mean, just look at the ideas they come out with sometimes …

But hands-up anyone who really does live in a virtual world, or at least has an online character that does?

Forget online gaming – the ‘in thing’ is now online living. Virtual worlds like ‘Second Life’ and ‘Kaneva’ provide an escape from the pressures of the real world into one where you can almost literally live a different life.

Except that these virtual worlds are eerily similar in their construction to the real thing. This is not online gaming with dragons and swords; this is an online second existence. Real-world currency can be converted into online currency. This can be used to buy food, land and homes. It can be used to gamble, buy pets and pay for online weddings. You can buy things, make things and sell things.

And yes, you can make a profit and the online currency can be converted back into sterling via your PayPal account and spent in the real world. Police forces and legislators are becoming concerned about the huge potential for money laundering. Several of these worlds boast the creation of real-world millionaires as a result of virtual entrepreneurial activity. Creative suppliers of consumer goods are already setting up virtual shops selling everything from t-shirts to construction companies.

The giants of the consumer marketing world are waking up to this potentially lucrative new advertising medium – Nike already have a formal presence in at least one major virtual world. So, what does this have to do with pharmaceutical marketing? Well, how long will it be before one of the big companies has a presence?

Pharma in a virtual world

Fanciful? Not at all. Already, it is possible to get ill and be treated within these virtual worlds. Doctors need medicines. Companies make medicines. Companies have competitors. Competition creates a need for marketers and sales reps. At least one of the advertising agencies known to our industry already has a presence in the virtual world: ‘Leo Ideas Hub’ is an advertising agency within the Second Life world and was set up by Leo Burnett and Arc Worldwide over two years ago. Of course, their market presumably does not yet include pharmaceutical companies developing material for virtual sales reps to use when promoting virtual medicines to virtual doctors. That’s a ludicrous idea. Or at least it might have been a few years ago.

Online gaming is seen as a natural extension to standard computer games; online ‘living’ is a natural extension to offline computer games like ‘The Sims’. Many computer games have long had scenarios where the characters get ill and need to be given treatment. Even Pokemons need to go to healing centres to maintain their fitness levels. The concept of illness and treatment is no different in the online world. It is true that virtual worlds are still in their infancy, but real-life human demand is driving increasing sophistication within the virtual worlds. Sophisticated virtual illnesses and the need for sophisticated virtual medicines are simply a further evolution.

In fact, the concept is already established. In August last year, a report in the Lancet (Infectious Diseases) highlighted the use of an online computer game to simulate the spread of disease. A ‘disease’ was inserted into the online game ‘World of Warcraft’. Starting in a small virtual village, the disease spread to the bigger virtual towns when online characters migrated across the gaming world in pursuit of their individual ‘quests’. As the disease spread to the cities, human ‘users’ sent their online characters to those cities and used their healing powers to cure the sick. However, the migration of the characters caused the failure of the quarantine zones that had been established around the virtual towns and cities by the real-life controllers of World of Warcraft, who were trying to prevent the ongoing spread of ‘disease’. The online migration patterns and real-life human motivators (such as a desire to help friends who were suffering) were monitored by real-life scientists. The results were credible enough that the Lancet gave the work publishing space. Such mass-scale research was presumably comparatively cheap, fast and safe, so we should expect similar examples of studies by certain sectors of the medical and market research communities.

But this is all still ‘theoretical’ – good for a story, but not likely to have a real impact on us soon, right? Don’t be so sure.

Online promotion of prescription medicines

The phenomenal influence of the internet has of course already changed huge areas of our lives. In the same way that the download charts replaced the singles charts when on-demand internet sites revolutionised the music industry, the internet is driving changes in other areas of our lives. And it is already happening – just ask anyone with an iphone, or try to remember the world before text messaging.

And, of course, the internet is bringing about rapid change across business world. Just about everyone with an e-mail account will have been offered the opportunity to purchase various prescription medicines (primarily treatments for erectile dysfunction) from online pharmacies. These spam e-mails are always from US sources, of course, because the UK doesn’t allow the purchase of medicines online; nor does it allow online promotion of prescription medicines.

Or at least things used to be that clear-cut. Boots recently complained to the MHRA about a company called Pharmacy2U, whose online presence in the UK offers to fulfil private prescriptions for prescription medicines. Boots alleged that the Pharmacy2U website breached the Medicines Act because it advertised the prices of prescription medicines and also compared those prices with the cost of prescription medicines available from Boots pharmacies (ie the site was advertising prescription medicines for sale to the public). The complaint was rejected because Pharmacy2U was not deemed to be advertising the medicine; the MHRA ruled that the site would only be of interest to patients who had already been diagnosed and were already in receipt of a prescription.

Even a cursory glance at the site (and others like it) reveals this to have been an interesting ruling. In addition to advertising lower prices on over-the-counter medicines, ‘P’ and ‘POM’ status products are also available from Pharmacy2U (and a number of other online pharmacies). A few, carefully selected, therapy areas are highlighted with comparisons of the features of different prescription products and the prices charged for fulfilling the prescription. No surprises for guessing that the therapy areas in question include erectile dysfunction.

In Pharmacy2U, a menu button at the top of the screen (‘prescriptions’) leads straight to information about fulfilling and obtaining online prescriptions. To the right of this page is helpful information about products such as Levitra, Cialis, Viagra, and prescription products in other therapy areas such as weight loss. The usual text appears with information about mode of action and side-effects, followed by helpful links that allow patients to visit ‘my online Dr’, where they can obtain a prescription that is then (equally helpfully) fulfilled directly by the online pharmacy.

Other hypertext links lead to a comparison table of the three erectile dysfunction products, including price comparisons.

Obviously, the online pharmacy services have been assessed by the MHRA and determined to have correct and proper controls. However, this particular distribution channel starts to raise some fascinating propositions and questions. For example, once the MHRA had deemed that the concept of online pharmacies dispensing prescription medicines was acceptable, it was only a matter of time before the big retail chains pitched in with their offerings. As in all aspects of commercial enterprise, it is likely that competition will continue to produce innovations in the available services, which will in turn pose further questions for the MHRA.

In January this year, a Google search using the term ‘online pharmacy’ (limited to sites in the UK) generated over 350,000 returns.

Pharmacy2U was listed second; first was www.onlinepharmacyuk.com. The text underneath its listing claimed: “The discount pharmacy store, internet pharmacy for weight loss pills, impotence treatment, buy Reductil, buy Xenical, buy weight loss pills, buy Viagra …” Payden’s, Boots, Lloyds and Phoenix all offer similar services, although with varying degrees of directness in their marketing approaches.

And if the retail chains can do this, so can hospitals, private clinics and dispensing doctors. So how long will it be before pharmaceutical companies are asked to sponsor such sites?

In fact, remember that in their ruling about Pharmacy2U, the MHRA stated that only existing patients would visit online pharmacies to get prescriptions filled. This means that pharmaceutical companies can legitimately put information for patients on those sites because it will count as ‘reference’ information under clause 22 of the Code, even though the sites blatantly facilitate the securement and fulfilment of prescriptions. In fact, a number of companies already provide links from their own UK corporate websites to companies such as Pharmacy2U and online prescription companies.

If we then consider the potential that online pharmacies offer pharma from the perspective of marketing’s four ‘P’s, a much-underused element becomes a realistic proposition. ‘Place’ (the distribution of product) has always been a difficult element to apply effectively in our industry owing to the limitations imposed by the need to obtain and fulfil prescriptions. It simply wasn’t possible to reach a large audience without suffering the margins of pharmaceutical wholesalers. Those companies who have recently been exploring innovative solutions to their supply chains by limiting the number of wholesalers, could theoretically improve their margins even further for some products by cutting out wholesalers altogether!

In fact, a pharma company could theoretically employ suitably qualified retail pharmacists who could dispense medicines and use their own wholesaler’s licence to provide medicine directly to their patients. Is it really that different from a partnership with Calea or one of the other home delivery services? Direct supply to patients shouldn’t be a problem because the MHRA have already approved it in the Pharmacy2U model.

OK, it might not be quite that simple, but it may not be such a leap of fancy either.

Compliance implications

Of course my personal interest in all this is not simply the marketing, but the compliance, reputation and ethical aspects that will exist in the future as a result of developments like online prescriptions and online information.

There has always been a need to interpret the grey areas in the ABPI Code to determine how it affects specific and unique circumstances. As technology has advanced, we have all had to grapple with the compliance implications of the changes – for example, how to approve new media such as text messaging, websites and e-detailing.

As technology continues to evolve, we have to figure out how to certify and archive ‘transitional’ media such as those generated by active servers, and how to cope with the plethora of mobile devices now available. Many companies have e-marketing specialists – how many have e-compliance specialists?

And aside from the technological changes, there is the need to consider the compliance aspects of other environmental changes too. How does clause 18 apply to a sponsorship application from a private company that makes its profits by supplying NHS services to NHS patients? Does such sponsorship still count as benefiting the NHS?

Actually, regardless of clause 18, what will shareholders say about the business ethics of pharma helping a private healthcare provider get richer? Some companies are already reluctant to support educational grants for employees of private hospitals, so how does practice-based commissioning fit into the equation now that GP income is more directly tied to the services that the GP provides?

Since the GP financially benefits (almost) directly from providing innovative services to patients, if the GP applies to pharma for sponsorship of those services, this may be construed as crossing the line and becoming an ‘inducement’. And that’s just from a ABPI Code perspective. A US law, the Foreign Corrupt Practices Act, (which covers payments from the US to government official or employees in foreign countries) may also have some bearing.

To return to the example of online prescription fulfilment, we now see non-pharma companies selling prescription medicines on the internet directly to the general public, while the industry that makes those medicines – and that the ABPI represents – is not allowed to. Surely pharma companies should be able to supply their products directly to their consumers? (Note I say ‘supply’, not ‘promote’.)

Certainly there is a need for greater clarity within the current ABPI Code of Practice for all types of online activity – everything from healthcare professionals ordering samples online to patient support programmes; from metatags to social networking sites. And that’s before we consider online pharmacies and their relationship with the industry.

And, of course, these are just the real-world challenges. I don’t know if Pharmacy2U or Boots have a presence in virtual worlds like Second Life. Assuming that some online pharmacies do, then surely those virtual shops sell ‘medicines’ to the avatars (virtual people). All shops need manufacturers to supply products.

It could be a great PR exercise for GSK to establish such a manufacturing presence. From there it is but a hop, skip and jump before there is a virtual PMCPA to monitor the virtual Code (virtual ABPI?) that governs the virtual activities in the online world.

And that opens a market for an online compliance consultant ¿

FACEBOOK FORCED INTO AN ABOUT FACE

The social networking phenomenon Facebook and its chief executive Mark Zuckerburg are at the forefront of personalised internet marketing.

As a pioneer, the company is exploring the boundaries of what it can do with the information and personal details its users supply.

In February the company had to swiftly back down from plans to lay claim to all photos, messages left on the site and other information – even after a user closed an account. After an angry backlash from users and commentators, the company was forced to back down, and retain its existing policy.

Steven Gray is a chartered marketer who lives in the real world (although some might dispute that) and specialises in healthcare sales and marketing compliance. He has an online presence at www.stevengrayconsulting.co.uk .