Our Healthcare Engagement Strategy Summit focused on examples of successful healthcare engagement – where pharmaceutical and device companies and government bodies used emerging channels to make a positive difference to their relationship with customers and patients, and in some cases, to change lives. All of our award winners had to overcome certain obstacles to achieve success, and many of these obstacles are perceived by many in the healthcare industry as reasons to not engage via emerging channels at all.
Being aware of the potential “dangers” of engaging online is important, as pharmaceutical companies must remain compliant with regulatory requirements. However, this awareness should drive responsible actions without ceasing engagement entirely. This article discusses why this is the case, and gives practical advice for companies who want to begin or develop their online engagement activities.
Adverse events
Pharmaceutical companies have a duty to respond to adverse events, and a key reason for reticence in opening up digital channels of engagement is the fear that this will lead to deluge of online Adverse Event Reports (AERs) that will overwhelm pharmacoviligance departments.
Careful planning, preparation and discussion with internal stakeholders is important here, as is making intentions clear – letting users know what the topics of conversation to focus on has been shown to be surprisingly effective in guiding the types of discussions taking place.
I spoke with Andrew Widger, Director of Media Relations for Pfizer EMEA, about the approach taken to online AERs by Pfizer:
“…Whether it’s a proactive listening project or a public awareness effort, we look to design it with the flexibility to pause at any point, should we start to find more AERs than we can manage effectively in the necessary timescale. This has worked well for us.”
His experience has been of low levels of online AERs:
“…Through the programme design, through positive moderation of any public discussions, and by clearly signposting the public to the appropriate places to report or discuss concerns about treatments, the experience to date has shown a low level of AERs coming from… [online] activity.”
Whilst it is important to respect the AER requirements, pharmaceutical companies should be reassured by the experiences such as these, which have shown that the dreaded flood of online AERs is unlikely, and that the risk of a difficult situation can be reduced by common-sense programme design and liaison with stakeholders.
Research by Creation Healthcare has shown that AERs found on social media do vary by channel, therapy area and product, and so it is also worth taking such findings into account when planning a campaign.
Breach of regulatory compliance
The industry is used to working within tight boundaries for traditional channels of promotion, but many pharmaceutical companies feel that the guidance around the use of emerging channels is not sufficiently clear. By engaging online, companies feel they are entering into a game where the rules are still being created, but where the penalties for breaking these rules are tough.
An example of this was the PMCPA code breach by Allergan, which resulted from activity on an employee’s personal Twitter account. At first glance, a situation where a company can be penalised for the activities of its employees on private social media accounts seems a good reason to avoid engagement altogether. However, it is worth considering that Allergan were charged with a breach of clause 22.1, rather than a more serious clause 2 breach, because it was clear that the company did have social media policies in place, and had been let down by an employee, rather than it being a case of the company acting wrongfully.
The lesson here is to ensure that governance is tight, and that training is in place. No company can control the activities of its employees, but by acting responsibly, and investing in these areas, a pharmaceutical company can reduce the risk of employees being involved in harmful activities, and can also protect itself should a problematic situation arise.
Being open to criticism, misuse of engagement forums
Digital methods of communication remove geographical boundaries and allow for the rapid interchange of information. Whilst this adds a new dimension to human interactions, it also means that bad news, or views, can travel very quickly. Additionally, the anonymous nature of the internet means that forums, YouTube pages and even Facebook pages can be environments where abuse is common.
For this reason, pharmaceutical companies might worry that the internet is an arena where reputations can be broken through the rapid spread of rumours and negative opinions. A recent example of how digital methods of communication were involved in the damage to the reputation and share price of a pharmaceutical company is the KV pharma crisis. Outraged by KV’s move to sell a product for preventing premature labour at an increased price, a mother from the US started a “Shame on You” Facebook page, and the story soon had worldwide coverage.
Once again, at first glance, this example suggests that being involved in the online space is risky – however, it is important to note that the company was not damaged through its online engagement activities, but rather by its actions outside the digital space. It could be argued that KV could have protected its reputation more effectively had it been more actively involved in digital communications.
Those that have been successful in the digital space, including this year’s HES Award winners have used episodes with detractors as learning experiences. A key point from our winning Roche case study is that it isn’t possible to control the conversation online. This view is supported in other areas of the healthcare industry, and I asked Dr James Quekett, Director of Educational Services at Doctors.net.uk about his experiences of managing disruption on professional forums:
“Doctors’ online communities experience similar challenges to other online communities…There is a small number of individuals who will simply seek to elicit reactions in the other users…The relative proportion of these type of users is very small, especially in a professional environment, but the disruption they can cause can be significant and can cause individuals or companies to disengage from the online space, this is exactly the response that these individuals crave and can be seen as their reward or victory…”
Simple measures, such as making the rules of engagement clear, and sensitively moderating the conversation can help companies to prevent and deal with disruption. The approach taken in a number of successful initiatives is to allow negative comments to remain visible – since most of those involved in the conversation have a genuine interest in engaging, the conversation “moderates itself”, with other users ignoring or challenging the negative comments. Decide in advance which sorts of posts will be deleted (e.g., those using foul language, or which are directly abusive to individuals or groups), and make this clear in the forum’s rules.
Key learnings
- DON’T let thoughts of being inundated by online adverse event reports (AERs) prevent you from opening up channels of engagement. Planning and preparing with your pharmacovigilance department in advance will help to handle the unlikely situation of an unmanageable volume of AERs.
- DO invest in governance and training. This will make for smoother-running campaigns, and can reduce the impact of problems, should they arise
- DON’T worry about how to control what happens on the internet – it isn’t possible
- DO be upfront with users about what can and can’t be discussed in a particular forum, and about which kinds of posts will be removed
- DON’T forget that the digital environment reflects what happens elsewhere, and vice versa. You need to plan for the impact of offline events, both positive and negative, on your digital forums, and conversely, findings from the digital space can be used to influence other areas (e.g., news often breaks first on Twitter – if you are actively monitoring this channel, you may gain an advantage when working with the media)
- DO plan your campaigns. Digital should not be considered a quick or cheap option – investing time and resources in the beginning will help to create successful, low risk campaigns
- DON’T be afraid of making mistakes. Prevent issues where you can, but when problems arise, use them as learning experiences
