Guest Columnist - DTC Perspectives

The recently passed Washington My Health My Data (MHMD) Act stands as a significant legislative milestone, reshaping data requirements for pharmaceutical companies and raises a new specter of non-compliance. Against a backdrop of increasing regulatory scrutiny and privacy concerns, understanding the implications of the MHMD Act is a critical first step and learning that they may not be in compliance is weighing on the minds of CEOs, CMOs and Chief Privacy Officers (CPOs) across the industry. Compliance Officers are asking what the impact of the MHMD Act will be, and, more importantly, how can they ensure that their companies are aligned with changing regulations?

What is the Legislation?

Enacted on March 31, 2024, the Washington My Health My Data Act represents a comprehensive framework aimed at enhancing health data ownership and privacy. Key provisions of the MHMD Act include obtaining explicit authorization from consumers before selling or sharing their health data, expanding the definition of health data to encompass various aspects of physical and mental health, increased transparency regarding data privacy practices, and stricter accountability measures in case of breaches or violations including enforcement actions by the Attorney General and private litigants.

Of course, the MHMD Act has profound implications for pharmaceutical companies, reshaping their approach to data privacy and compliance. In an industry characterized by stringent regulations and waning consumer trust, adherence to the MHMD Act is critical for several reasons, not the least of which being Regulatory Compliance. Healthcare companies operate within a complex regulatory landscape, subject to oversight from federal agencies such as the FDA, FTC and DEA. The MHMD Act introduces additional compliance requirements, necessitating proactive measures to ensure adherence and avoid negative PR and costly penalties.

Identifying the source of one’s FOFO: Fear of Finding Out

Pharmaceutical companies, their agencies, and internal compliance have always been a critically important part of program execution, but the stakes have just gone up. In fact, in this new compliance environment, one could now consider a proactive approach to data compliance management as a competitive advantage for the business. Specifically, the companies with the right approach and toolset to automate workflow, will have a new competitive advantage whenever engaging in marketing programs and at all digital consumer touchpoints. It also means the end of FOFO, because finding out about your level of compliance shouldn’t be a fearful situation.

Shailee Vimadalal, a partner at ZS Associates is a global management consulting and technology firm specializing in transforming healthcare and beyond said about these marketplace changes, “The Washington My Health My Data Act (MHMD) brings a renewed focus on consumer consent for data use by the US pharmaceutical industry. This necessitates investments in personal data collection and handling practices to ensure greater transparency, commitment, and control for the consumers on how their data and how it is being used. Implementing a robust consent and preference management solution can be a strategic step for pharma companies to navigate this evolving landscape.”

In the pharmaceutical industry, ignorance is never an acceptable reason for being out of compliance. In addition, once a company becomes aware of an issue, its leaders are obligated to act.

This draws a direct line from the CEO to the office of Compliance and across to the head of IT as Data Management challenges begin to emerge. Pharmaceutical companies handle vast amounts of sensitive patient data, including clinical trial results, medical records, and adverse event reports. Laws like this touch even simple “request more information” type functionality on product websites and extend throughout all brand digital media. Compliance with the MHMD Act requires attention to robust data management systems to safeguard the privacy and security of this information.

This Washington act will also impact Marketing Practices. The MHMD Act’s provisions for consumer authorization and data-based targeting have significant implications for pharmaceutical marketing strategies. Companies must ensure compliance with opt-in requirements and adopt data privacy-centric approaches to these campaigns while ensuring strict compliance with data-usage disclosures. In other words, proactive and skillful compliance in marketing workflows will become a key strategic and tactical competitive advantage for pharmaceutical brands in 2024.

Pete Dannenfelser, a pioneer of digital healthcare marketing communications, offers insights into the impact of the MHMD Act on pharmaceutical company compliance. “The industry’s historical commitment to conservatism and caution may make change easier. But the consequences of non-compliance underscores the importance of leveraging tools to assess the current state of a company’s digital platforms and readiness for what’s next.”

Dannnfelser goes on to say, “While these newly enacted requirements will hit the entire industry, pharmaceutical companies operating under Corporate Integrity Agreements (CIAs) must be able to act quickly to uphold stringent compliance standards. Non-compliance with the MHMD Act could jeopardize adherence to CIAs, leading to severe consequences.”

Amidst the challenges posed by the MHMD Act, Dannenfelser recommends leveraging new AI-powered digital tools to navigate compliance requirements effectively. In fact, adding these powerful new tools to workflow should foster a competitive advantage, not only in day-to-day tactical execution, but also with strategic planning in a rapidly evolving new regulatory environment.

“Advertisers can only effectively manage what they can measure, so optimal integration of compliance standards into workflows become an essential element of all digital media campaigns and web properties,” says Jamie Barnard, CEO of COMPLIANT, the industry leader in AI SaaS compliance software.

A.I. algorithms analyze vast amounts of data to assess compliance risk levels, identifying potential areas of non-compliance and guiding companies in prioritizing remediation efforts. These learnings can help pharmaceutical companies create comprehensive compliance roadmaps, outlining steps to ensure compliance with data privacy regulations, opt-in requirements, and data-based marketing practices. Beyond that, AI technologies enable real-time monitoring of compliance activities, allowing companies to detect and address compliance issues promptly and proactively, minimizing the risk of regulatory violations and associated penalties. As any seasoned Rx marketer can tell you, a little proactivity can go a long way when dealing with regulatory bodies.

The Washington My Health My Data Act ushers in the next era of significant regulatory data requirements with far-reaching implications for the healthcare industry among others. So, what should pharmaceutical companies be doing now to manage FOFO and stay ahead of this and other emerging data laws?

Embrace A.I.-driven tools to reactively assess active current content and proactively review new digital assets.

Adopt proactive compliance strategies leveraging tools and revising policies to be flexible enough to change with new laws.

Respond quickly when issues are identified – oftentimes, the remediation is not as intimidating as it seems, especially if repeatable processes and guidance is enacted.

Ian Wolfman & Pete Dannenfelser

What’s happening with TikTok?

As many of you have heard, TikTok has been formally banned in the U.S. (it will take effect by January 2025 at the earliest). The major reason for the ban is the national security threat from the Chinese government, which could potentially use it to spy on Americans or weaponize it to covertly influence the U.S. public by amplifying or suppressing certain content. While TikTok management is willing to fight the ban in court and looking for various workarounds, it is forecasted that the platform will most likely be purchased by one of the U.S. tech companies. Under the bill, TikTok will now have 270 days to divest. However, an additional provision could also see TikTok apply for an extra three months under certain conditions (e.g., if it’s negotiating with buyers and needs more time to finalize the deal).

We already see conversations around potential platform buyers. Experts say that Meta is the least likely candidate in this case, and it is more realistic to consider companies such as Oracle, Microsoft, Walmart, and Triller.

What does it mean for us as pharma marketers?

It is hard to predict how the platform will evolve if TikTok wins its legal case or if either of the players acquires it. This means it is too early for pharma marketers to consider future strategic considerations.

Regardless of the outcome, it’s obvious that the situation casts a shadow on the platform’s reputation in the eyes of pharmaceutical marketing stakeholders who were considering it for potential social initiatives. It also may affect the U.S. social media landscape, where we can expect a spike in snackable video content on Instagram Reels or YouTube Shorts driven by migrated U.S. influencers.

We haven’t had a chance to produce any content for the platform in the past due to regulatory implications on our clients’ side. However, we are currently working on Instagram and Facebook Reel ads development for clients, which is a great opportunity to start exploring the format deeper as an alternative to TikTok.

When considering influencer marketing, it would be fair to eliminate TikTok as a platform for potential partnerships and focus on Instagram and YouTube. X (former Twitter) is a questionable platform for HCP influencers as it is still experiencing some market backlash and had a 7% drop in brand use in 2024.

The upcoming changes aren’t supposed to significantly affect the way we’ve been strategizing our clients’ social presence. However, we should keep exploring alternative platforms to help brands engage effectively with patient/HCP audiences while keeping a close eye on the next steps on the TikTok side. As an agency committed to staying ahead of the curve, we’re prepared to navigate these changes alongside our clients and help them thrive in the evolving social media landscape.

Helen Hoye

Healthcare providers are analytical and methodical professionals who make important decisions every day affecting the lives of their patients. Constant learning is critical to their performance.

But HCPs are also human, with egos, personal lives, daily pressures, and jobs that impose long hours and high demands. Their time and attention are at a high premium.

To effectively educate HCPs about a brand and differentiate it in their minds, marketers must optimize product messaging so that it quickly and vividly resonates with each audience segment. An effective tool for doing this is heuristics, a term that encompasses a process of psychological shortcuts that simplify and accelerate decision-making.

We all use heuristics in our everyday lives, especially when faced with new or high-volume information and a limited time to process it. In a stressful situation, for example, we might base our response on how we successfully handled a similar situation in the past.

In healthcare marketing, there are numerous heuristics domains that commonly affect the decision-making of HCPs. Some of these include:

Background Contrast Effect: People are more likely to select an option when an inferior choice is present, i.e., they judge an option based on its contrast with a lesser option rather on its merits.

Instant Return: People want a return on their investment (time, effort or money) immediately.

Novelty Bias: People often think newer is better.

Negativity Bias: People pay more attention to and give more weight to negative things than positive things.

Zero-Risk Bias: People prefer reducing a small risk to zero rather than making a larger reduction in a bigger risk.

Understanding and prioritizing which heuristics are applicable in a specific situation – i.e., which are most relevant to target HCPs and pertinent to the features of a particular brand – is an important step in developing effective brand messaging. Here are some examples of how heuristics can guide and optimize messaging.

If the dominant heuristic is Instant Return, optimized messages will focus on how quickly results can be expected, e.g., “Observable results in two weeks, with proven significance at six weeks,” or “Improvement you and your patient can both see in as little as six weeks.”

If Novelty Bias is the dominant heuristic, what’s new and unique about the product will be the focus, e.g., “Only Product X has once-daily dosing and no meal restrictions, which may help your patients remain compliant.”

Similarly, if the dominant heuristic is Background Contrast Effect, optimized messaging will emphasize the drawbacks of an inferior choice (such as remaining untreated for a particular condition) to underscore the value of a different option, e.g., “The impact of body movements isn’t just physical; even mild body movements hold patients back from making meaningful connections and performing daily tasks”.

Of course, optimized messaging isn’t the end of the story. The next step in successfully connecting HCPs to a brand is delivering those messages through powerful creative that communicates quickly and is pertinent, impactful, and memorable. Powerful creative is also visually compelling – studies show that the vast majority of human communication is nonverbal, people process visual information much faster than text, and they retain more of what they see than what they read or hear.

Ultimately, powerful and effective creative is distinguished by four key hallmarks. First, it’s quick, to the point, and communicates in the blink of an eye. Words and pictures work seamlessly together to deliver a disarmingly simple idea. Second, it’s relevant, telling a meaningful story that resonates with viewers and indelibly marks the brand message in their minds. Third, it makes an emotional impact, connecting with the hearts and minds of viewers and communicating benefits, not just product features. And fourth, it’s distinctive, standing out and delivering a message so fresh, daring and different that it’s impossible to overlook.

Optimized brand messaging that is guided by heuristics and realized by powerful creative is a solid foundation for effective advertising and a confirmed way of connecting HCP’s to your brand.

Jody Van Swearingen

The transformative power of artificial intelligence is just beginning to be realized in pharmaceutical marketing. While machine learning and AI have been around for years, it’s only recently that we’ve found ourselves in what I often describe as a technological Wild West. (Interesting sidenote affirming my choice of words: AI summarizes Wild West as “a complex and multifaceted period blending adventure, danger, and the pioneering spirit of those who shape the frontier.”)

Expanding into new territory is always challenging and perilous, especially for heavily regulated industries. With new AI capabilities and tools cropping up regularly and every industry trying to figure out the best way of harnessing them, pharma marketers have been advancing into AI cautiously.

Social media analysis is one of the first areas where the industry began successfully using AI tools. This involves extracting information and deriving insights from user-generated content across all major social media platforms globally. Using AI models enables pharma companies to identify trends with unprecedented scope and speed and gain real-time insights into public sentiment and patient needs.

As pharma marketers continue assessing AI and its significant opportunities, following are some important ways AI can be used to enhance DTC marketing.

Getting Personal: Personalized marketing is a key area where AI-based research models provide great value. Using AI tools to evaluate a variety of data – including social media engagement, click-through, and bounce rates – gives DTC marketers a deeper understanding of the patient journey and the touchpoints and issues that impact it. Ultimately, this information can drive more sophisticated targeting strategies and more relevant, personalized messaging. It also helps marketers anticipate market shifts more quickly and be more agile and focused in responding to them.
Growing Sentimental: Using AI to analyze unfiltered customer feedback on social media and review platforms gives DTC brands the ability to proactively address patient concerns and urgent issues. For example, a Facebook user posting a question about a new drug may immediately get hundreds or even thousands of comments addressing the query. An AI-powered tool can evaluate the posts in real time, assess opinions expressed, indicate misperceptions, and flag commentaries that require a proactive reply. AI-assisted sentiment analysis can also identify what social media groups and influencers are developing around a specific disease state or drug. This enables pharma marketers to provide more relevant content, helping to increase conversion rates.

Correction Please! AI models are also useful in stopping the spread of misinformation and disinformation. By rapidly evaluating huge data sets and targeting the origins of bad information in real time, AI enables pharmaceutical companies to respond to misinformation both quickly and directly at its sources. This, in turn, can help companies correct the record and establish greater trust in their brands. Imagine if AI had been further developed during the pandemic to respond to the disease and vaccine misinformation prevalent at that time.

While the sophistication and accessibility of AI tools are thrilling, DTC marketers still need to balance traditional market research with AI-led models. Traditional market research generates large volumes of in-depth information, but that data is very time-consuming to analyze and limited in scope. AI-driven research is fast and broad in scope, but still subject to bias and misinterpretation in some areas, e.g., it can misinterpret sarcasm or context-specific nuances, which may skew results. The best approach for DTC marketers is to identify and verify where AI-driven research can most effectively complement traditional research and develop an integrated strategy that optimizes both.

While we don’t know what the next election will bring, we do know that privacy and governance in AI will be on the table. Pharmaceutical companies and their agencies must develop their use of AI within a strong data-governance framework, always asking themselves what the ethical boundaries of AI are and how data privacy and online patient information can be protected. Without this focus on privacy and governance, the industry risks major setbacks and penalties in its adoption of AI. Protecting the autonomy and privacy of the individual remains paramount.

Ultimately, the goal of using AI in DTC marketing is to help consumers better understand their health, the diseases that affect their health, and the options available for preventing, managing and treating those diseases. With imagination, skill, and proper guardrails and compliance, AI could well usher in a transformative new era in DTC marketing.

Sharlene Jenner

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ECG keeps a watchful eye on trends in women’s health. In 2023 we saw a birth rate that stabilized overall, with variability at local levels; unit closures; growing demand for high-risk services; and provider shortages. Will those trends continue in the new year?

Here are five key drivers that we expect to shape women’s health services in 2024.

Consolidation, Closures, and Growing Maternity Deserts

ECG has written on OB unit closures and the resulting maternity deserts, which are largely driven by industry-wide staffing shortages and pressure on health systems to remain financially sustainable. This year, we foresee an increase in provider group consolidation as OB/GYNs seek relief from burdensome call demands. Impacts to patient access will be substantial; limited resources will be focused on the necessary coverage of inpatient services, to the detriment of outpatient care.

Implication: This is an opportunity for providers to differentiate themselves in their markets and serve their communities in new ways, such as reimaginging care team structure/roles, seeking new partners, embracing innovation, and enhancing operational efficiency.

The Rise of Care Teams

As physician recruitment becomes more challenging and financial headwinds mount, successful women’s health programs are approaching care teams from a holistic perspective. To create the most efficient care model, health systems are partnering with obstetricians, midwives, doulas, physical therapists, and APPs to form teams that promote an expanded scope of services to meet patient preferences while allowing each team member to practice at the top of their license. These team-based models offer many advantages, including:

Expanded access through greater coverage and schedule availability.
More effective and culturally competent care delivery.
Increased patient and workforce satisfaction.

Implication: Creating a care model that coordinates and effectively communicates activities across functions and team members is key to overall program success. Identifying governance, span of control, and agreed-upon care standards is essential to ensuring quality is maintained while care models evolve. The consensus-building process is the most critical component to this type of work, so proper staff and provider involvement is imperative.

Investment in Women’s Health

Market fragmentation, enhanced consumerism, and rise in overall demand for women’s health offerings has drawn the attention of private equity (PE) investors. Investment in women’s health services has more than tripled in recent years, and more deals are anticipated in 2024 as venture capitalists see opportunities in areas such as fertility/reproductive health, menopausal medicine, coordinated pregnancy care, and postpartum recovery. Investment drives innovation, as seen by the multitude of new technologies and services emerging in the women’s health sector. Depending on the perspective, specific investments may be considered a welcome addition or additional hurdle for providers.

New care models offer opportunities for diversification for systems looking to expand their offerings with fewer resources. Apps, digital patient education, home monitoring, and virtual services augment the traditional patient care experience.
Women’s health is becoming an increasingly competitive space. New service provider entrants to the market offer medical services to niche patient populations, potentially siphoning patients who may otherwise have sought services from existing providers and facilities.

Implication: Rapid innovation and technology gives providers an opportunity to differentiate their offerings. Providers should be watchful of the investments in women’s health and consider the impacts to their organizations. As PE investment expands, most health systems will have to make a choice: compete directly with PE-backed companies through targeted alignment, acqusition, and investment in incubator spaces, or partner with PE firms in a structure that maximizes capital investment and the system’s own management expertise.

Focus on Quality and Access

The maternal mortality rate continues to rise, particularly for women of color. In 2022, the White House released a Blueprint for Addressing the Maternal Health Crisis, which puts an increased focus on addressing quality and access challenges for maternal care. The report recommends several initiatives—including an expansion of programming, an increase in price transparency, and the “Birthing-Friendly” designation—that will shape the future of women’s healthcare services by holding facilities accountable.

Implication: Strategies to support operational efficiencies (particularly around outcomes) will be imperative to remaining competitive. Providers and facilities should consider targeted investments, establish transparent communication/marketing positioning, and optimize outpatient operations to remain financially sustainable.

Changing Regulatory and Legislative Landscape

Providers face a fluid regulatory and legislative landscape, which will continue to impact access to services as well as the cost of doing business.

Reproductive Health: Access and regulations have changed on a state-by-state basis, potentially shifting the provision of services and resulting risk. Structuring meaningful care pathways will help organizations to maintain quality and outcomes while mitigating risks.
Malpractice Costs: Costs for malpractice insurance are already among women’s health providers’ greatest expenses, and obstetricians are the most likely of all physicians to be sued for malpractice. While malpractice caps help balance providers’ risk, several states are proposing increases to those caps—which would heighten financial risk for providers. This may prove to be a driver of change among provider groups, adding pressure to consolidate practices, discontinue services, or retire earlier in an effort to reduce risk exposure and expenses.
Chaperone Laws: State requirements for chaperoning physical exams vary, but women’s health providers are the most impacted. These laws continue to evolve—as is evident from recent legislation in Oregon and Wisconsin—and have the potential to impact business operations via staffing and workflow adjustments.

Implication: For many providers and facilities, women’s health is a core service—a foundational offering that must be provided regardless of the constraints. The key will be the ability to shift through changes and create operations that will enable healthcare providers to remain sustainable—and potentially grow—in an uncertain environment.

Tessa Kirby

The LGBTQ+ community encompasses a wide range of patients across all races, ethnicities and gender identities. However, when seeking healthcare resources and support, many of these patients feel underrepresented and mistrustful of pharma advertising, new data shows.

Less than half (44%) of LGBTQ+ patients feel that pharma ads reflect their experience as members of the LGBTQ+ community, according to survey data collected by Phreesia Life Sciences and Klick Health from more than 1,500 patients in early 2022 as they checked in for doctors’ appointments. Similarly, only 45% of surveyed LGBTQ+ patients feel that pharma understands their unique needs, with those who identify as transgender or female being even less likely to feel understood by the pharma industry.

This lack of representation and understanding has affected LGBTQ+ patients’ overall trust in pharma, with 2 in 5 surveyed patients (41%) reporting that they don’t trust pharma ads at all and another 26% saying that they trust them “only a little.” And while representation is vital for building and maintaining that trust, outreach to the LGBTQ+ community also is crucial for bolstering these patients’ confidence in pharma, says Thea Briggs, Associate Director, Content Strategy, Phreesia Life Sciences.

“Representation matters, but it’s not enough to address disparities on its own,” Briggs says. “Pharma marketers must actively pursue robust outreach efforts, such as learning about LGBTQ+ individuals’ healthcare experiences, hiring LGBTQ+ people and partnering with community organizations to create effective campaigns, as well as dedicating consistent energy and attention to addressing the issues that this community experiences.”

Those issues range from having higher rates of either being uninsured or underinsured to postponing or avoiding medical treatment because of bias and discrimination. Additionally, although more than 50% of surveyed LGBTQ+ patients say they are aware of many preventive care services, the percentages of those who have recently used such services are much lower. For example, while 59% of LGBTQ+ patients are aware of blood-pressure screening, only 32% got screened in the past year.

As for outreach, many LGBTQ+ patients feel that pharma still has more work to do: Slightly more than one-third (34%) of surveyed LGBTQ+ patients “strongly disagree” and another 22% “somewhat disagree” that the pharma industry conducts sufficient LGBTQ+ outreach beyond HIV and pre-exposure prophylaxis (PrEP) medications that high-risk individuals take to prevent getting HIV.

To improve LGBTQ+ patients’ perceptions of the pharma industry, as well as their preventive care knowledge, Amy Gómez, PhD, Senior Vice President, Diversity Strategy, Klick Health, emphasizes that it’s important to include members of the LGBTQ+ community at every stage of the pharma-marketing process, including foundational research and concept and message testing. Doing so can help pharma companies develop a deeper understanding of these patients’ attitudes, beliefs and behaviors and ensure that those attributes are accurately reflected in pharma communications.

“We can and should use our skills to create empathy and urgency,” Gómez says. “We can partner with our clients and providers to develop model programs that demonstrate the positive effects on community health outcomes when empathy for LGBTQ+ people and awareness of the health issues that impact them help to ameliorate implicit bias.”

And while engaging with LGBTQ+ patients to better understand what they need from their healthcare experiences can help boost preventive care usage, Phreesia survey data shows that greater inclusion also translates into more opportunities to positively impact LGBTQ+ patients’ perceptions of the pharma industry. Overall, 82% of surveyed patients said they have more positive feelings toward pharma companies that conduct outreach to the LGBTQ+ community.

“We’re proud to be using our platform to connect with members of the LGBTQ+ community to learn from them directly about their experiences in navigating and accessing healthcare,” says David Linetsky, Phreesia’s Senior Vice President, Life Sciences. “Our hope is that the insights we generate from this work will help advance and guide efforts among providers and pharma manufacturers to address biases and create more equitable healthcare experiences for these communities.”

Actively engaging with members of the LGBTQ+ community and gathering data that educates providers and better equips them to meet these patients’ needs is crucial for continuing to build their trust in the pharma industry, Briggs explains. However, fostering that trust must be a broadly inclusive, long-term commitment for life sciences organizations if they want to make true progress within this community.

“It’s easy for marketers and public health professionals to fall into the trap of becoming prescriptive— assuming we know how problems are experienced by individuals without asking them and deciding that we’re going to go in with our preferred solutions, regardless of community buy-in and participation,” Briggs says. “That’s not effective or respectful. Building trust and designing effective interventions and campaigns that will be well-received and work in patients’ real lives requires a lot more listening and learning than talking.”

Jackie Drees

It was a typical Thursday morning in Medical, Legal, and Regulatory (MLR) review, and we were about to review a simple branded banner ad for a prostate cancer drug. The team has always been accustomed to allotting 15 to 30 minutes at most to review a tactic as simple as a banner ad, but this was certainly not the case that day. The banner ad was pulled up onscreen for review and within two seconds of it being displayed, the legal reviewer abruptly said one word: “Nope.” Everyone in the room and on the phone was confused, so naturally, the lead marketer asked if there was a problem. The legal reviewer explained that the first frame of the banner ad displayed an African American male representing a patient with prostate cancer, and then the reviewer followed up by indicating that the prominent use of an African American male misrepresented the brand.

Before diving into the rationale that this legal reviewer provided for this decision, let us briefly discuss the reality of the prostate cancer patient population. This year, an estimated 268,490 men in the United States will be diagnosed with prostate cancer. The number of new cases diagnosed in Black men is 73% higher than the number of new cases diagnosed in White men. Black men in the United States and the Caribbean have the highest incidence rates of prostate cancer around the globe.¹ In addition to being more likely to be diagnosed with prostate cancer, African Americans have the world’s highest incidence of prostate cancer and a more than two-fold higher mortality rate compared with White men.²

Now back to the MLR review where the legal reviewer refused to review the banner ad due to the representation of the patient in the first frame. You could hear a pin drop in the room when this decision was made. There was an overwhelming sense of discomfort among the marketers, ad agency partners, and even certain MLR review team members, especially since this was at a point in time when we as a nation were at the height of sensitivity around racism and racial disparities, including health disparities. It was at a time when Diversity, Equity, and Inclusion (DE&I) was at the forefront of corporate culture across all industries in our nation. But let it be clear that this legal reviewer was not acting on or making a decision under any racial or prejudicial ideologies or ways of thinking. The legal reviewer stated that we were misrepresenting the brand because the clinical trial of the product we were promoting had less than 1% African American patients represented in the study population. Consequently, this reviewer deemed it as a substantial legal risk to prominently represent an African American male on a branded piece promoting the product. All other reviewers then followed suit and the decision was made to replace the Black patient with a White patient—all because it misrepresented the clinical study population when in reality, it was most representative of our national population fighting prostate cancer.

The intent here is not just to tell a story about an instance that occurred in one MLR review, but to use this story to set the stage on a topic that runs rampant in the pharmaceutical and healthcare marketing and advertising industries. The topic of patients being underrepresented or misrepresented in marketing efforts across various disease states is neither novel nor unique. It has been an issue plaguing the pharmaceutical and healthcare marketing industries for quite some time now. Although many companies are actively attempting to address this issue, especially with the recent uptick in DE&I efforts, we still have a way to go when it comes to matching our industry’s multicultural representation with the multicultural reality. Therefore, the intent here is to briefly highlight just a select few of the fairly recent and successful trends in our industry that are being used to combat this issue, with a focus on three specific points: (1) representative clinical trial recruitment, (2) representative patient inclusion within pharmaceutical advisory boards, and (3) the importance of effective multicultural marketing.

Representative Clinical Study Recruitment

Let us first address one of the main principles that will help shift the narrative of multicultural representation in the pharmaceutical industry, which is the corporate recognition that multicultural recruitment efforts for clinical trials need to be significantly better and truer to the epidemiology of each respective disease state’s population. Ensuring people from diverse backgrounds join clinical trials is key to advancing health equity.³ Participants in clinical trials should represent the patients who will use the medical products. Unfortunately, this is often not the case as people from racial and ethnic minorities and other diverse groups are underrepresented in clinical research. So, while it may seem obvious, one significant step researchers and medical product sponsors can take to confront healthcare disparities is to ensure clinical trials for medical products are more inclusive of multiple populations.

In fact, the US Food and Drug Administration (FDA) issued final guidance in late 2020 with the agency’s recommendations of designing and executing clinical trials of drugs and biologics that include people with different demographic characteristics (e.g., sex, race, ethnicity, age, location of residency) and nondemographic characteristics (e.g., patients with organ dysfunction, comorbid conditions, and disabilities; those at weight range extremes; and populations with diseases or conditions with low prevalence). This guidance provides the FDA’s current thinking on steps to broaden eligibility criteria in clinical trials through inclusive trial practices, trial designs, and methodological approaches. In turn, it aims to provide recommendations for how sponsors can increase enrollment of underrepresented populations within their clinical trials.⁴

Ultimately, this will allow medical product manufacturers to reach their respective patient populations more accurately and effectively through even more targeted marketing efforts. It will also help prevent any uncomfortable conversations around potential risk due to legal technicalities associated with clinical trial recruitment and promotion of the product at hand.

Representative Patient Inclusion Within Pharmaceutical Advisory Boards

It is exceedingly important to understand that now, more than ever, patients of all socioeconomic or demographic statuses have access to self-research medical information. DeepIntent fielded a study in which they found that while stuck at home during the pandemic, people saw more pharma ads than ever and it was not just on televisions, but on computers and mobile devices. The study also found that consumers watching ads and searching for health information online weighed almost equally when measured against their physician-provided knowledge.⁵

As patients take their health and future into their own hands with the help of digital health tools, they also should be treated as equal partners within hospital, pharmacy, and even pharmaceutical company settings. For this reason, pharmaceutical companies are increasingly employing patients who have experience with the given company’s products on their advisory boards, and better yet, accurately represent the most affected patient populations. This allows companies to capture detailed patient information to inform future strategies and effective targeting approaches.

As an example, Novo Nordisk is committed to incorporating the patient voice at all stages of their product development process. They believe it takes a multistakeholder approach to develop new treatments for patients living with chronic diseases, and Novo Nordisk is convinced that patient partnerships are the best starting point for all medical innovations. As a result, in 2020, Novo Nordisk established patient advisory boards called DEEP (Disease Experience Expert People), which is a framework for placing patients center stage and providing an environment for their input to affect the patients’ care delivery model, as well as future patient communication strategies for Novo Nordisk products.⁶

Importance of Effective Multicultural Marketing

Multicultural marketing is the process of representing diversity within a brand’s collateral, messaging, and content, as well as speaking directly to diverse cultures, races, and groups. The multicultural or cross-cultural segment constitutes the largest, fastest-growing consumer segment in the US market. This is due to the significant treatment gaps across therapeutic areas that not only represent potentially millions of new scripts but also represent the strong brand upside and a reputational boost from the opportunity for the pharmaceutical industry to improve patient outcomes on a national scale. The multicultural segment is also at the forefront of the consumer movement when it comes to digital, mobile, and social media use and when communicated in a way that is relevant and resonates, has a higher promotional response. To address this growing populace, the number of pharmaceutical companies investing in multicultural marketing teams has more than tripled within the last decade. The good news is that although the industry is a bit behind, the needle is certainly moving in the right direction as many pharmaceutical companies have also adopted multicultural or multiethnic corporate strategies.⁷

A key part of effective multicultural marketing is that to close some of the gaps, an incremental investment is needed to specifically target these audiences, as traditional efforts can prove less effective. Using Nielson media data, a direct example of this can be seen in a breakdown of primetime TV viewers. When the top 10 English language networks were compared to the top Spanish language networks, it was determined approximately 70% of US Hispanics (18 years or older) are exclusively tuning in to the Spanish-speaking Univision. The data clearly show that traditional investments in the English language TV space are underreaching this audience.⁷

It is also important to gain the necessary vocabulary and language for essential conversations around cross-cultural marketing and to hear directly from leaders in cross-cultural marketing on how to create a business case for the investment internally and how best to collaborate successfully externally. Consideration of necessary ways to apply existing tools and data sets to communicate with a diverse audience more effectively is what sets apart a truly successful multicultural campaign from the status quo. For example, social media marketing and the content shared on various platforms, should mirror the diverse audience it’s targeting and seek to engage them, which will undoubtedly prove far more successful than those brands choosing to employ a more blanketed approach, designed to appeal to a broader and more general audience. Now is the time for marketing teams to appropriately budget for a targeted multicultural, multichannel approach to adequately communicate health information directly to communities of color through the specific platforms where they most engage. The inevitable result? Better DE&I practices by marketers, better brand visibility and results, and more informed and engaged target audiences.

In conclusion, a key takeaway is that multicultural marketing is simply marketing. It should now be the standard across any marketing strategy throughout any industry. But when speaking directly to the pharmaceutical industry, the main point is that patients want to be heard and most importantly want to understand treatment options available for their conditions, and that especially goes for the most at-risk patients, which for the most part, happen to be ethnic minorities in low socioeconomic geographic areas. However, it will be difficult to notice a significant shift without effectively addressing at least the three trends that were just highlighted: (1) representative clinical study recruitment, (2) representative patient inclusion within pharmaceutical advisory boards, and (3) the importance of effective multicultural marketing. It is imperative that all three items feed into each other, and as such, strengthen each other when done properly. Lastly, it is critical for the pharmaceutical companies in collaboration with all their partner agencies to continue to fight for appropriate, accurate, and necessary representation of patient populations not only as they pertain to clinical studies, but as they are truly represented in those most affected, especially in the underserved ethnic minority communities. Because as many of the team members in that MLR room reviewing the banner ad that one Thursday morning can attest, they never want to have to sit through a conversation like that ever again.

References

Cancer.Net®. Prostate Cancer: Statistics. Accessed July 20, 2022. https://www.cancer.net/cancer-types/prostate-cancer/statistics
Hoffman RM, Gilliland FD, Eley JW, et al. Racial and ethnic differences in advanced-stage prostate cancer: the Prostate Cancer Outcomes Study. J Natl Cancer Inst. 2001;93(5):388-395. doi:10.1093/jnci/93.5.388
Clinical Trial Diversity. US Food & Drug Administration. Accessed July 20, 2022. https://www.fda.gov/consumers/minority-health-and-health-equity/clinical-trial-diversity
FDA Offers Guidance to Enhance Diversity in Clinical Trials, Encourage Inclusivity in Medical Product Development. US Food & Drug Administration. Accessed July 20, 2022. https://www.fda.gov/news-events/press-announcements/fda-offers-guidance-enhance-diversity-clinical-trials-encourage-inclusivity-medical-product
The Patient Perspective: Paving the Path to Awareness, Ad Relevance and Empowerment. DeepIntent⁺_®. Accessed July 20, 2022. https://www.deepintent.com/the-patient-perspective-paving-the-path-to-awareness-ad-relevance-and-empowerment/
Coquerel C, Kuruvilla S, Eichmann L. Inside Novo Nordisk’s Patient Advisory Board Meetings. Accessed July 20, 2022. https://www.clinicalleader.com/doc/inside-novo-nordisk-s-patient-advisory-board-meetings-0001
Nielsen. The Multicultural Edge: Rising Super Consumers. Accessed July 20, 2022. https://www.nielsen.com/wp-content/uploads/sites/3/2019/04/the-multicultural-edge-rising-super-consumers-march-2015.pdf

Mo Hamzeh

The patient experience at the point of care is rapidly changing. Today, medical groups continue to implement more consumer-centric workflows and digital engagement platforms to manage operational, clinical and financial processes. While the COVID-19 outbreak accelerated the adoption of these tools among providers, it was not the initial catalyst. Prior to the pandemic, many healthcare providers had already begun to adopt digital engagement tools to manage operational, clinical and financial processes. Phreesia’s patient intake platform was designed to support these trends, which has allowed us to quickly adapt to the current industry environment and to deliver valuable applications to our provider network and the broader market. We recognized the urgent need for intake products that could support telehealth visits, screen for COVID-19 risks and minimize contact during in-person visits and shifted our efforts to helping medical groups stay safe, stay open and continue to see patients. As we navigate a new normal in a post-COVID-19 world, we believe digital engagement tools will become even more critical to ensuring that the POC stays relevant to Life Sciences manufacturers and healthcare marketers.

The evolution of the patient experience during COVID-19 has brought POC marketing to a tipping point. Today, amid tremendous disruption to the U.S. economy and healthcare industry, marketers are questioning whether the POC is still an effective environment to engage with patients. The answer is yes, but to be effective, healthcare marketers must adopt new standards for success that consider the realities of a post-COVID-19 environment and how patients and staff are adjusting to a different kind of intake experience.

Below are five important changes that we believe the POC marketing industry must address:

The POC is no longer tied to physical locations—it’s wherever patients choose to engage with their providers and seek care
In-person visit volumes are fluctuating and have created tremendous uncertainty for advertising exposure and impression volume, making one-to-one engagement tactics more valuable
Increased provider sensitivity to shared surfaces will decrease the effectiveness of many traditional marketing tactics
Patients are more receptive to personalized content that’s tailored to their individual health needs
Disruptions in patients’ access to care has created a greater need for support programs

The POC was moving beyond the walls of the physician’s office well before 2020, but COVID-19 has led to specific workflow changes that are likely to become the norm and as a result, will impact the future of POC marketing. Medical offices have implemented contactless, or “zero-contact” workflows to help minimize exposure and reduce contact between patients and staff. Many of our clients have eliminated the waiting room by asking patients to wait in their cars when they arrive for their appointment and to check in using their mobile devices. They’re also removing shared surface spaces and assigning the majority of their non-provider staff to remote work. Telehealth has also brought significant change to POC marketing. Prior to COVID-19, the telehealth market was dominated by specialty services offered through employee benefits plans. But as healthcare organizations look for ways to provide care and limit contact between patients and staff, a growing number of them are offering virtual visits. The result of these operational changes, both contactless workflows and telehealth, is a more personalized intake experience that relies on patients using their mobile devices to engage with providers outside of the traditional office setting.

Even as medical groups rebuild their appointment schedules and patients begin to return to their providers’ offices, it’s clear that the overall the nature of in-person visits, including opportunities to engage with patients during those sessions, has changed. As more providers adopt telehealth and zero-contact workflows, we’ll need to find new ways to measure impression volumes that were traditionally based on the in-person visit. We can no longer rely on patients’ idly reviewing screens, thumbing through magazines or picking up brochures and pamphlets in the waiting room. We’ll need to deliver targeted, one-to-one engagements to patients’ mobile device, while also ensuring that the content is restricted for their personal use only.

In addition to facing a new intake experience, patents today are inundated with new information about their health. As COVID-19 guidance and recommendations continue to evolve and patients navigate through a constant stream information, medical marketing must be personalized to patients’ specific health interests and concerns. Those solutions that are tied to office operations, rather than a specific office location, will stand out. Healthcare marketers can leverage self-service digital platforms, such as patient intake software, to engage with patients about their health. At the same time, the one-on-one nature of these personalized engagements have a far greater chance of catching patients’ attention. The point-of-care offers us an opportunity to reach patients at a critical point along their healthcare journey—the moment when they are most attentive to their health concerns and just before they speak with their provider about those needs.

COVID-19 also caused a tremendous disruption to patients’ access to care. The initial outbreak forced many medical offices to close or to reduce operations, delaying care for hundreds of thousands of patients. Sadly, it also exacerbated social determinants for many patients, including employment, health insurance and education. Today’s patients need more than just information about new therapies, they need to learn about diseases and to understand the importance of resuming treatment protocols that may have been interrupted, such as vaccine schedules, infusions, preventive health screenings and diagnostic testing. We also need to ensure they’re aware of the numerous patient support programs available from life sciences manufacturers. These programs can be invaluable in helping patients gain access to and stay on therapy, yet fewer than one in five patients are aware they exist. Increasing visibility of these programs is critical for improving patient adherence, as well as to ensure that qualifying patients can access the right therapies to achieve their health goals.

As we enter a new media planning season, healthcare marketers and life sciences manufacturers need more detail and strategic insight into how the POC can become an integral part of their digital and mobile strategy. Patient utilization data demonstrates the value of mobile and how it enables provider to deliver safe care via zero-contact workflows and telehealth services. We must also personalize content and create directed, one-to-one engagements to cut through the noise and influx of health information aimed at patients to address their specific needs and priorities. Finally, we should incorporate disease education and patient support programs into digital engagement campaigns when they can improve health outcomes for target patient populations. As the patient experience becomes increasingly mediated by the converging forces of digital adaptation, patient centricity and pandemic response, we must find a way to align our digital engagement strategies at the point of care to every patient’s needs.

Click here to learn more about Phreesia’s digital engagement solutions.

David Linetsky