Pharma likes to put itself in a very specific frame: They are makers of our “Brussels sprouts.” No one wants to take their meds, or go to the doctor, or track their progress. These are chores we all simply have to do. And while Pharma is fully engaged in finding and designing new Brussels sprouts to make us healthy, they throw a sidelong glance at the idea of adherence. You can almost hear pharma say, “It’s good for you, so just take your meds while we get back to making new ones.” They leave it to the prescribers and pharmacists to scare patients into adherence. But adherence is key to pharma’s success in the long run. Low adherence reduces the likelihood or curing or treating the disease, which lowers patient’s interest in taking more meds. If we instantly hit 100% adherence, pharma sales would be way up and we’d hear less doom and gloom at industry conferences.
So let’s look at someone who’s gotten the idea of adherence right and see what we can learn. Fitocracyis a site designed to get people to take a different kind of medicine: Exercise. Excluding those handful of crazy people who consider exercise fun, most Americans look at time at the gym or on the treadmill as a chore even more dreadful than swallowing some pills. Yet somehow, Fitocracy has levered a number of different psychological and sociological tricks to get people to commit to getting more fit, and then doing the work required to get there. How successful is Fitocracy? In a world where startups are desperate for people’s attention, Fitocracy’s site is invite-only, and it took a little effort for me to get in. In a nutshell, Fitocracy gives you points for being physical. You get points when you work out, but you also get points when you shovel snow, or take the stairs instead of the elevator (granted, you get a lot more points for deadlifting half your body weight than you do taking the stairs, but it all adds up). There are pre-assigned quests and achievements you can complete (like when you log 10 items in a week, or try a barbell squat). And as you add workout data, you can level-up, like in a video game. And like a video game, each level gets a little harder to achieve, but by the time you’re working towards level 10, you’ve got weeks of workouts under your belt and you have the confidence you can complete the level without it being too easy. Aside from the game tricks, Fitocracy leverages the power of each person’s personal network. Just as you will gain weight when you hang out with over-eaters, and get funnier when you hang out with clever people, hanging out with people who work out encourages you to work out. Hanging out with people trying to lose weight helps you look at your choices in a new light. On the site, your social network gives you props for good workouts or when you’ve had a couple of good workouts in a row. Or when you lose a few pounds. Or when you set a record on the treadmill or barbell. You get positive reinforcement, right there on your screen every time you work out, along with points for giving your friends props, encouraging you to give as well as you get. No friends? Join one of the existing groups, like the Chicago group or the weight loss group to achieve your goals. You are collaborating together, and that induces even more adherence. This is social proofing: you don’t want to let your friends down, and they don’t want to let you down.
How can pharma steal some tricks? Well, if pharma wants to start using the ideas of persuasion, gamification and social proofing to increase adherence levels, it needs to start by getting out of its own way. Especially in terms of privacy. Yes, pharma succeeds because of federally mandated privacy laws, but as you can see from the thousands of patient forums, people are willing and interested in talking about their disease state so long as they get the choice to do it on their own. Pharma can play a part, and even encourage people to talk amongst each other without coming anywhere near violating privacy rules. They can build a site like Fitocracy devoted to diabetes or gastric distress or gout or depression, where patients get points for doing things that make them healthier (like taking their meds), or talking to other people with the same disease, or helping other people with their problems. Beyond the obvious health benefits to the patient and adherence benefits to Pharma, this community could serve as an active focus group, one that can help you understand patients and even leverage should you need to communicate with patients or the public at large. Pharma needs to become partners with their patients to solve a lot of each other’s nagging problems, and it seems Fitocracy has developed a pretty interesting template on which to model that solution. If you’re looking for Fitocracy invites to check it out, ask me on Twitter: @digital_pharma!
You’ve read the FDA’s new partial guidelines for pharma in social media titled “Responding to Unsolicited Requests for Off-Label Information About Prescription Drugs and Medical Devices,” right? (If you haven’t, go now. We’re all waiting. Try Dose of Digital or Fierce Pharma.)
Okay, so in a nutshell, if I’m reading this right, it says that pharma companies are allowed to respond to people who post in private and public internet spaces about off-label uses of their drug. But have to respond privately. Specifically, these are unsolicited requests, so you can’t coordinate with your marketing company to seed the idea that Brand XYZ cured baldness. There are some other considerations, but that’s the gist. (Those of you waiting for complete guidelines from the FDA should get comfortable, because if this is what we got in a year or two of discussion, you’re in for a long wait.)
So, here’s what is interesting:
1) The words “liability,” “expectation,” or “anticipate” are nowhere in this document. The FDA is not yet ready to place the burden of having to listen to every online channel on pharma. Yet. So pharma can hang back and choose not to get involved in social if they don’t want to because the FDA is not forcing them to.
2) The rules for what pharma is allowed to say seem to differ depending on whether or not the request came in public or private, despite the fact that the answer must be private. (Private requests will answer scientific questions with scientific information, public requests will pretty must stick to the label and ask the requestor talk to a healthcare professional.) Thus, the same questions asked in two different medium might get two different responses.
3) The FDA is saying while pharma can respond to all unsolicited requests about their own brands, they have to respond privately. But we all know in social media nothing stays private for very long.
Let’s walk through a scenario to see how these new rules are applied.
So I write Brand XYZ and ask them a question. The brand is now allowed to respond privately, but they, as good corporate pharma citizens, must be “truthful, non-misleading, accurate and balanced,” and include standard response information. Then, I go on Twitter and ask the same question and get a different response via DM or email. This isn’t much on the surface, except that the FDA has done everything to keep pharma from ever saying anything anywhere that hasn’t been reviewed seven ways to Sunday. The review process is the FDA’s way of getting everyone to stick to the script (because it’s far cheaper to stick to the script than to try something new, and gamble on whether it survives medical, regulatory and legal reviews). To allow two different responses from pharma on the same question is new.
But since the FDA is quite clear on keeping those responses private, maybe it thinks it can control the message in the world’s most porous communication environment. Which would be silly.
So either A) the FDA is asking pharma to do nothing new (i.e. “stick to the script, kids”) or the FDA is anticipating (or worse, not realizing) that every private response will quickly be copied and pasted into public forums all over the internet, thus negating the FDA’s own intent of keeping off-label information private.
On one hand, the new guidelines seem to focus on solving a very narrow problem in social media. On the other, the FDA may be trying to learn how quickly these “private” messages will become public, indicating that the FDA is serious about understanding the social media environment–not just in theory, but in practice.