For the third time, Vodori sponsored eXL’s Promotional Review Committee Best Practices conference held in Morristown, NJ last week (September 23-25, 2019). With over 100 regulatory, marketing, and marketing operations professionals in attendance, the conference continues to be an excellent forum for discussing the latest trends and challenges in promotional compliance in the life sciences industry.
This year’s conference offered great speakers with diverse opinions and experiences. Despite these differences, a shared theme emerged: technology both supports and challenges the promotional review process. Many presentations spoke to this common theme and provided key insights around changes we can anticipate as technology continues to change at an increasing rate:
1. “Diversify the Use of Social Media and Advertising Promotion.”
Kate Ho and Anita Kachappilly summarized the challenges and considerations associated with the most frequently used social media platforms for advertising and promotion in their talk, “Diversify the Use of Social Media and Advertising Promotion.” Kate and Anita shared how Facebook’s recent update reduced the lines of text displayed before a video or image on a mobile viewport–from 7 lines of text to 3. This seemingly small change can have serious regulatory implications if safety information or a link to the PI is truncated as a result. With 96% of Facebook users accessing the platform via mobile devices, it’s essential that PRC teams review Facebook posts in both mobile and desktop viewports. Overall, the presentation emphasized the importance of PRC teams having access to dynamic tools, like Pepper Flow Digital Review, at their disposal to reduce process complexity and give reviewers the most accurate representation of digital advertising.
2. “Ad Promo Enforcement Trends and Insights.”
The rising prevalence of social media influencers was broached in Kimberly Belsky’s discussion of “Ad Promo Enforcement Trends and Insights.” Taking a look outside the U.S., Kimberly discussed the July 2019 decision by the U.K.’s Advertising Standards Association (ASA) against Sanofi UK regarding the use of a “celebrity” for paid promotion of medicines–a violation of the Code of Non-broadcast Advertising and Direct & Promotional Marketing (CAP Code). The “celebrity” involved was a blogger/influencer with 30,000 Instagram followers. The ASA’s decision reinforced the need for PRC teams to carefully consider paid social media tactics. Before electing social media as a tactic for a product or campaign, consider:
- When is a blogger/influencer considered a “celebrity”?
- What constitutes a “significant following” on social media?
- Does influence vary by therapeutic area or disease state?
Ensuring that all promo review participants are conversant and educated on social media tactics and terminology will help PRCs act as a guide and enabling resource for commercial teams, rather than a time-consuming gatekeeper.
3. “The Rise of New Technologies and Best Practices for Applying FDA Promotional Guidelines.”
Linda Pollitz and Tiffany Mura gave us a glimpse of the future in their presentation “The Rise of New Technologies and Best Practices for Applying FDA Promotional Guidelines.” Sharing perspectives from marketers and regulatory professionals respectively, Tiffany and Linda discussed how voice-activated search, digital health devices, and text chatbots present new considerations for promotional review processes. With devices such as Amazon Echo and Google Home becoming more ubiquitous in homes, consumer’s use of voice-activated search suggests that PRC teams should consider the unique behaviors and underlying technologies of this new form of search. Voice SEO ranking is different than text-based search as it serves up more organic, colloquial search terms and longer search queries. As a result, marketers want to ensure that webpage copy reflects the broader terminology associated with the product and disease indication; regulatory teams will want to ensure that any search results follow the appropriate guidance for disease awareness ads or include the required fair balance for any branded or product material.
The proliferation and increased adoption of technology will continue to create opportunities for life science organizations to better meet the needs of patients, providers, and payors. However, for promotional review teams to continue to be viewed as effective, trusted partners in commercial operations, they will need to get comfortable, conversant, and compliant across digital channels and platforms.