8 Tips to Take the Fear Out of Interactive Promotional Media


Social networking concept

Recently, Institute Biochimique got its “hand slapped” by the FDA because of its hypothyroid drug Tirosint’s Facebook page.  The page was subsequently removed after the FDA concluded that the drug’s manufacturer omitted risk information about the inability of the drug to treat obesity and weight loss, as well as the drug not being suitable for children.  The FDA has proved it’s watching: do you think it’s worth the risk for medical companies to engage in social media?

Examples like the Tirosint Facebook page, offer a possible explanation as to the reasons many medical device and pharmaceutical companies are resistant to integrating various streams of social media such as Facebook, blogs, and Twitter, due to the inherent risk posed by real-time engagement with potential patients.  However, with the growing increase of social networking, directors of marketing are eagerly looking for an approach to manage engagement throughout the various channels of social media.  The FDA’s recent draft guidance released in January of this year, attempts to narrow down the ambiguity over user-generated content (UGC).

Here are 8 tips to take the fear out of Promotional and User Generated Content based on the FDA Draft Guidelines:

1. When in doubt, Submit to FDA per Postmarketing Submission Requirements.  The FDA says in the draft recommendations that it “recognizes the challenges of submitting promotional materials that display real-time information.”  In recognizing this, a firm that follows the proper postmarketing submission requirements will receive, “enforcement discretion regarding the regulatory requirements for post marketing submissions related to promotional labeling and advertising.”  A best practice for medical device and pharmaceutical marketing teams would be to maintain a habit of continually keeping the FDA informed by submitting your FDA 2253 or FDA 2301 and additional information as specified in part V.

2.  Submit If You Place It, Manage, or Review Content.  Product promotional messaging on Twitter, Facebook, or your company’s blog, for example, and other types of digital content you create and place in various social channels, come with the added responsibility for submitting this information to the FDA as required by postmarketing submission requirements.  This also applies if your company is managing the material creation, editing it, or giving approval.

3.  Submit If You Pay for a Third-Party Site.  When your company pays, or has any kind of editorial influence over the material on a third-party site, then you must submit.

4.  Don’t Submit If You Pay but Don’t Have Control.  The example given by the January 2014 FDA Draft Guidelines is if your company pays for a third-party site “through an unrestricted educational grant” and your company has no access to control or manage the site, then you don’t have to submit content to meet post marketing submission requirements.

5.  Don’t Submit UGC.  If you don’t have control or influence the UGC on a site under your control, or there is UGC on a site you don’t control, you don’t have to submit.

6.  Submit if You “Like”.  If your company representative responds to UGC or “Like’s” something, then you will need to submit.

7.  Submit if the Content Is Generated by Authorized Company Representative.  Your company is responsible for any content created by those employees and sales reps promoting products for the firm, “A firm is responsible for the content generated by its employees or any agents acting on behalf of the firm who promote the firm’s product.”

8.  Submit Content from Paid Bloggers.  A paid blogger’s content would need to be submitted per FDA postmarketing submission requirements.


Trending Now: App Repurposing



Mobile devices have become “the great communicator” for businesses and most companies have adopted some kind of mobile footprint.  This footprint may be as simple as using off-the-shelf App Store apps or as far reaching as adopting enterprise-wide platforms that provide services such as syncing content on team members iPads or providing CRM and other data sharing tools across the enterprise.

A new trend that is starting to generate interest is repurposing of existing apps.  With the Apple App Store approaching one million apps, some thought leaders have started to look at how apps developed for one purpose can be repurposed for similar-but-different needs.

An example of how app repurposing is providing benefit can be found in health organizations that are gathering health metrics in developing countries.  A surprising increase in the accessibility of mobile technology in remote and previously “un-wired” communities (think of cellphones in Mongolia) has allowed healthcare watchers to start gathering health related metrics from remote regions.  These groups have found simple ways to repurpose existing apps for little or no cost.  Apps can often be repurposed without modification by using the app differently (e.g. putting blood pressure values into zip code fields in a cloud based mobile address book).  When no app will fit a need, these groups may approach the developers of an existing app and ask if they would make small changes to support a needed feature.  Jan Edwards of Paving the Way has been working with several countries in Africa to collect health metrics using this approach.

Looking at things differently is one of the talents we have at Tricycle Studios.  Let us show you how thinking differently can benefit your organization.


The Doctor Won’t See You Now

Ironically, the best bet to increase sales reps’ in-person interaction time is better digital engagement.

Doctor Wont

This story isn’t new to anyone in healthcare sales: Reps see their access to physicians dwindling.  We all know that.  The bigger questions for marketers and sales leaders are, why and what can we do about it?  I was hoping you’d ask that.  There are two significant influencers in the decreasing access to doctors and one clear way to address them.

Why: Age & Organization
The doctors who have been working with sales reps throughout their careers are being outnumbered by new, younger doctors who have not experienced value from relationships with reps.  It’s not just their age that’s changing the in-person visit dynamic, though. Around 70 to 80% of these larger organizations enforce limitations on how often physicians can see reps. With 90% of new doctors joining health systems after graduation, these restrictions are a major factor affecting the doctor and rep dynamic.

More Why: Value
Both younger and more experienced doctors, whether in group practices or independent, show a strong preference for digital contact. Physicians’ busy schedules require them to make the most of every interaction.  Respondents say that digital sales materials, such as emails, e-details, websites and social media, provide greater value because they are more flexible and provide personalized content.

When doctors do see reps, they primarily look to them for product information.  They cite printed and digital material as preferred resources for clinical information.  There is a lot that we can learn from this.  For reps that are selling commodities or disposable goods, this may not be tremendously important; for those trying to reinforce their role as a trusted information resource, this is crucial.

What We Can Do: Bring the Value
First and foremost, reps need to be better equipped to bring value to a clinical conversation.  They need the training and the tools to support real clinical conversations, conversations that uncover needs physicians face in their practices, and offer solutions.

Specifically, medical sales teams need interactive digital tools to engage doctors.  If doctors are already comfortable with digital contact, let’s use that to elevate the role of the rep rather than replace it. For example, digital follow up sent directly from a rep’s iPad-based e-detailing tool during a conversation gives the customer personalized information that she can review at her convenience and more value from the meeting.

Many no-see restrictions are the result of doctors feeling that their time has been wasted by reps.  To increase face time, reps have to increase value.  52% of physicians surveyed agree that the role of the sales rep needs to evolve.  All of this means one big opportunity for medical sales organizations to maintain their role as trusted advisors by more effectively leveraging digital engagement strategies.