How to: Influencer Marketing Guidelines for Pharma
The Pharma industry has been working with new and different marketing styles since its inception, testing the limits and finding out what works. Known for their use of Pharmaceutical reps and TV advertising, they now enter the new age of “influencer marketing.”
As a highly regulated industry, Pharma has many more rules than most industries when it comes to marketing. For other industries, a brand chooses an influencer who has a substantial and authentic following, complements the brand’s identity, and also has a desired audience demographic that the brand aims to reach. With Pharma, that becomes more complicated.
Recently, Kim Kardashian spoke out about her morning sickness by featuring a brand name drug to treat the common pregnancy side-effect on her Instagram account. The post immediately received negative responses leaving the marketing world with many questions on approaching influencer marketing.
The Regulations and Guidelines for Pharma
Even though it is a new sector of marketing, there are some regulations in place for Pharmaceutical interactions with influencers, depending on the location. Let’s compare the US and Canada for argument sake. Here in Canada, Kim Kardashian’s post may not have made it to print. There are rules in place that prohibit Pharmaceutical companies from engaging with an influencer for the purpose of promotion, unless they are a licensed healthcare professional (HCP). And even if the influencer is a validated health care professional, there are still strict rules of engagement to follow. These rules include the disclosure of side effects, and the disclosure of the intended use and purpose of the drug for treatment of specific ailments or inflictions, to name but a few.
In the US however, the rules are quite different. According to PhRMA “Direct-to-consumer (DTC) advertising of drugs has been legal in the USA since 1985, but only really took off in 1997 when the FDA eased up on a rule obliging companies to offer a detailed list of side effects in their infomercials.” Aside from the legality surrounding Pharma DTC, the industry itself has been pushing for further development of regulations by the FDA for online DTC, as marketing methods change. As mentioned in a peer reviewed medical journal, “These regulations could include mandatory public notification when online content is sponsored by a Pharmaceutical company. It has also been recommended that drug companies be made responsible for correcting user-generated content that makes unverified, negative, or clinically inappropriate comments.”
In addition, there are high level guidelines provided to those approaching any form of drug advertisement, including the FDA’s “Bad Ad Program”. This is aimed to prevent Pharmaceutical companies from misrepresenting themselves. The guidelines advise to be accurate, balance the risk and benefit of information, be consistent with the prescribing information approved by the FDA, and only include information that has been verified.
The FDA has released a draft of recommended practices for social media marketing, however no solid green light has been given to this practice, involving third party postmarketing just yet.
In the guidelines, it is recommended that any Pharmaceutical company choosing to engage with third parties, be it medical professionals or key opinion leaders (influencers) are obliged to be transparent in disclosing their involvement on a site or post, by clearly identifying the communications of its employees or paid opinion leaders acting on behalf of the firm. This allows Pharmaceutical companies to employ spokespeople, such as celebrities and athletes to endorse their products through social media. This being said, Kim’s post has also been criticized as having failed to represent her as an individual, and for being too branded. Her fans are struggling with this contradicting her statements about posting to her Instagram in the name of business. This controversy also reflects poorly on the brand and may have generated some unintended negative attention to the drug.
So, what does this all mean?
Evidently, the Pharmaceutical industry has to jump through quite a few flaming hoops just to ensure the appropriate, compliant execution of marketing campaigns. This is to be expected, given the responsibility to ‘do no harm’.
To its credit, the Pharmaceutical industry has since moved on from their long-time successful marketing style, including radiant smiles, lustrous persuasion and inappropriate gifting to physicians. A style accurately depicted by Jake Gyllenhaal in Love and Other Drugs 2010, where Gyllenhaal portrays a Pharmaceutical rep in the 1990’s, during the height of the ‘share of voice’ era where Pharmaceutical representatives were inundating doctors’ offices in record numbers, laden with gifts, incentives and ample Pharmaceutical goodies.
But times are changing. Share of voice on the streets has been augmented, and in some instances, replaced by ‘blogger influence’.
To avoid controversy over your Pharmaceutical influencer outreach, there are several steps and resources we recommend you could follow to ensure a seamless campaign:
1. Do your research
Using web resources such as PAAB (Pharmaceutical Advertising Advisory Board) in Canada, FDA (Food & Drug Administration) and DTC guidelines (US) to ensure that all steps you take in Influencer Outreach are within the legal limits of advertising.
If you are in Canada, implement the use of registries or databases that can verify the certification of the HCPs you choose as influencers. One such database is PTM (Professional Targeted Marketing). If you are in the US and running an influencer campaign, it is best to use validated medical experts even though it is not mandatory at present. The ABMS (American Board of Medical Specialties) Certification Matters website is an great example of such existing registries.
2. Be mindful of the influencer you choose
Choose an influencer who will advocate or use the drug for its indicated purpose. Using an influencer who may be known for using/abusing the drug for something other than what it is intended not only will misrepresent your drug, but may also reflect poorly on the brand, and perhaps lead to some legal issues.
3. Authenticity is key
Allow the influencer to speak in their authentic tone and personal brand, and not merely copy and paste a description or comment written by the Pharmaceutical company. This may devalue the authenticity behind the influencer’s opinion of the product, and could leave a bad taste in the mouth of consumers and audience members, seeming too forced and perhaps insincere.
There are a number of factors that need to be taken into consideration when a Pharmaceutical company is implementing an influencer marketing campaign. But this shouldn’t deter Pharma from adding influencer outreach to their marketing mix.
By following the industry guidelines and regulations in each company’s respective regions, and by implementing campaigns through established best practices, influencer marketing can be an effective approach, with positive outcomes for both the brand and influencer.