DTC and New Messaging Methods for Pharma in Canada
Aspen Pharmacare Canada Inc.
Pharmaceutical Advertising Advisory Board
In our sixth episode, Peter Brenders, Founder & President of Kontollo Health, talks with Mike Egli, General Manager of Aspen Pharmacare Canada Inc., and Patrick Massad, Commissioner of the Pharmaceutical Advertising Advisory Board (PAAB), about digital marketing to doctors and direct to consumer (DTC) advertising in Canada.
Thank you for downloading the sixth episode of the NPC podcast from the National Pharmaceutical Congress. This program is all about discussing and considering the purpose, process, and people of the pharma industry during the time of Covid. Today we’re continuing the health care conversation by answering questions sent by listeners like you.
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On today’s podcast for August 12, 2020, our guests are Mike Egli, General Manager of Aspen Pharma Canada and Patrick Massad, Commissioner of PAAB. Once again, your host for today’s podcast is Peter Brenders of Kontollo Health.
But first, here’s Mitch Shannon of Chronicle Companies. Over to you, Mitch.
MITCH SHANNON (MS):
Liona, thanks for your intro.
The NPC podcast was created to find you some informed answers to all those questions we have about the life sciences business and what our world is going to look like after Covid.
And if you have a question to ask, call our comment line at any time at 647-875-9011.
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For 25 years, pharma marketers in Canada have watched the US experiment with direct to consumer advertising: DTC. That is, we’ve literally watched countless DTC ads on American cable TV, even as Health Canada continues to restrict pharma advertising here.
So, how do you explain these two solitudes when it comes to DTC. Are we Canadians missing something? Or have the Americans been getting things wrong all this time?
To discuss the subject, Peter Brenders speaks with PAAB commissioner Patrick Massad and Aspen Pharma’s Mike Egli. Let’s listen.
PETER BRENDERS (PB):
Welcome to the NPC podcast. I'm Peter Brenders, your host. Joining me today is Mike Egli, Canadian General Manager of Aspen Pharma Canada, Inc. and Patrick Massad Commissioner for the Pharmaceutical Advertising Advisory Board: PAAB.
So, let's start with Patrick. Patrick PAAB’s the agency the pharma industry goes to for review of its promotional product communications. In these Covid times, it would seem communications may be changing. What do you see as the big advertising or marketing changes to healthcare practitioners?
PATRICK MASSAD (PM):
Thanks for having me on, Peter.
Yes, we've seen some rather substantive changes in Covid, both from a quantitative and qualitative perspective. Quantitatively we've seen an increase of 35% relative to last year in email and internet type advertising promotional systems divisions. So that's a sizable increase that's driven some qualitative changes as I mentioned earlier, as well in terms of more segmentation. Segmentation tends to be easier to accomplish, I guess, or more conducive in a digital forum. So that's actually led to higher submission volumes as well. So are reviewers are actually very busy. At the moment, we're seeing more segmentation both from a demographic point of view and also from from a value graphic point of view, which is interesting. We're seeing a lot of that now, more so over time.
I think at the beginning, closer to April perhaps, companies were more just digitizing print pieces and sending them out by email. I think we're seeing more of that digital first kind of approach now with the whole "okay, well if we're going to do this, how are we going to segment? What kind of variable fields are we going to apply to our pieces so that were able to quickly segment based on C, B or C. That's affected our volume, it's affected the amount of work we're doing, and it's affected a lot of stuff.
So, Mike as a company and living with sort of these same changes, you guys must be going through them as well thinking about a new approach to sort of marketing and advertising. So what would you add to Patrick's thoughts on some of these changes?
MIKE EGLI (ME):
So, I'd like to ask Patrick a few questions first, if I could.
Patrick, in your exposure that you've had over the last few months, are you approving items that are going to specific individuals? Or are they more campaign-based approvals that you're doing?
Well, it's interesting when you think of an email the answer is both, right? Because I mean in email, by definition, it appears in an individual's box. Having said that, it's appearing in several individuals boxes. So that is part of a campaign.
So yes, of course, that is reviewable material, as opposed to a true unsolicited, one on one correspondence of "I'm Dr. So-and-so, I'm reaching out to Company X's medical department to ask a very specific question. I'm going to get an answer that's very specific to that." That's an entirely different beast that's not subject to advertising regulations, but certainly an email campaign, although it's sent to individuals would most definitely be subject to advertising. regulations. And yes, that falls under pretense.
And have you seen a shift from campaigns going from health care professionals to consumers?
On the consumer front, I should disclose that the lion's share of what we review is healthcare professional advertising, it's actually 70% of what we review. 25% or so is patient information that's provided through healthcare professionals, a lot of people call that consumer, but that's an entirely different animal. And then there's the consumer segment, which is to the general public. It's only about 5% of what we review, but I mean, yeah, we do provide that service.
Are there shifts? That's always actually been more either broadcast or digital from our mix. When we look at our submission mix. We break it down between healthcare professional, patient, and consumer. They've always been different, which is interesting. Tends to have more of that one on one face to face deal with the healthcare professional. And as you get closer to the consumer kind of part of that spectrum, it's much more digital.
So, has that changed as a result of this? No. From what we've seen? No, what's really changed is the shift from the healthcare professional perspective, because there was less of it. I mean, we're going from, say, 35%, from an absolute basis to close to 40% for internet or for direct mail, which is mostly emails in the HCP context. So, that's a rather substantial shift for them. Whereas in the other areas, there hasn't been all that much change.
I can get you to write my marketing plan!
So, Peter asked a question, and I'm sort of just struggling with a few things. One is in the last eight years of my life in commercial, everybody talks about the patient. You know, the patient, the patient journey, the patient is the center. I even had one manager said I should have an empty boardroom seat in my management team meetings for the patient.
So, I'm struggling with, okay in this Covid-19 era the patient is even more vitally important. I'm not affiliated with a strong US company. So, I look to the US and I watch the US evening news every night, because I'm interested in watching it. And the commercials are all pharma commercials. And they're all biologics and other specialty drugs from big companies AbbVie, Merck, Takeda. You know, the list goes on. And they've been doing this for years. And they're pretty sophisticated companies, so I'm sure they have an ROI on it. I'm sure they've done the research to see how it works. The best way to do it. I'm sure they've done research to find out if it upsets the doctors, you know, to do this. I'm sure they have all that data I'm not privy to it because I'm not connected to it.
But then I asked myself, if they're doing this in the US, and maybe because their prices are so high, their margins are so good they can afford it. In Canada, our prices are lower. We also have other things that we pay for that other countries don't pay for. So patient support programs, etc all come out of the industry. So our margins are squeezed a little bit there. So I don't know if the economics is there.
But I wonder how Covid-19, if it's not an impetus to understand how Canada and how companies should be looking at how they can connect with the patient in a more robust fashion, educationally, commercially. I mean, you could argue that yeah, these commercials in the US are pure advertising, but they're doing it. Is that bad? Is that wrong? We can advertise like any other industry, maybe. But in Canada, we have different restrictions on consumer advertising. I don't think Innovations Canada has as a group said, "Hey, can we we open this up to something like the US and start approaching different stakeholders to discuss it?" And maybe it's because the economics don't make sense in Canada.
But even that aside, that's why I asked a question about have companies tried to shift to patients because I think in this pandemic, patients are the ultimate stakeholder. And companies are not going to be able to rely on traditional methods to get their medicines to the appropriate patient for the appropriate indication. And so that's something that I put on the table when we had a discussion about a month or so ago. Just looking in that direction.
You raised some interesting points. Although the mix hasn't shifted from a patient consumer or healthcare professional perspective, qualitatively, the information that's provided to patients has changed somewhat because of Covid and in very interesting ways.
So, for example, it kind of really highlights how positive of a role industry can play with patients. For example, say I'm on some sort of injection. I'm no longer going to my physician. Remember, the clinic no longer sees me, how am I supposed to get this thing? So, the advertising promotional systems that we review have very much changed to address and anticipate, and very early on, it's actually quite impressive how quickly people were thinking of these issues before they even became issues. And of course, PAAB, we expedite those to get those out as quickly as possible.
But it is impressive how quickly industry kind of helped patients adapt to this new reality. Although, you know, we haven't had pieces about Covid-19 specifically, and only because well, frankly, there are no products at this moment, although one's just been approved for the condition. But there are a lot of pieces that speak to how this context impacts you, the patient and how you can address or mitigate the complications.
Beyond that you touched something really interesting there as well in terms of the effectiveness, I guess, of DTC and whether you know, is it worthwhile, is it not? Is it ethically right isn't ethically wrong? They are very strongly opposing schools of thought on that. And of course, PAAB is completely agnostic as to whether or not people promote DTC or not. What our concern is, is simply follow the law. We don't advocate for any type of advertising, nor do we advocate against, we advocate for high standards.
So, that's what we're focused on. In terms of effectiveness. I've actually seen some studies that speak to this very matter. Yes, there's been a spike in US DTC ads in the question of how effective have they been is actually quite answerable. Obviously, consumers have been consuming media to record levels in consuming television, everybody is watching the news, seeing what's going on with Covid. They're seeing these advertisements, the question is, are they doing anything? I've seen several studies that indicate that, for example, when they have a call to action to go visit a website, the needle hasn't really shifted.
And that brings me to another point. It's not that DTC is good, bad, effective or ineffective, I said we have no position on this. But there is an abundance of research that shows that when the healthcare professionals involved, so as opposed to the direct to consumer realm, when we're communicating through the healthcare professional or that doesn't just mean verbally, but through pamphlets or through emails that are sent from healthcare professionals or on digital platforms where the healthcare professionals involved in some way, that's where you get the adherence to the message. That's where you get the impact. That's where you get the change in behavior and the recall. PAAB plays a huge role there, that falls into the patient information law.
So yeah, that's exciting. There are ways to make things more effective. It's not a matter of is it right or wrong, it's a matter of how do we do it in a way that's ethical, accurate, complete?
So, what I'm hearing here is the industry is anticipating questions to help patients find their way through information in these Covid times. To your point, Mike talked about DTC which we see in the US. Patrick talked a little bit about the for and the against that might be out there. But is that the middle ground for Canada, perhaps?
In terms of, that we're anticipating questions, that direct to consumer engagement in the Canadian market might be a little bit different. But again, more direct in terms of anticipating questions.
I think from my perspective, my portfolio, I don't have products that I would do it with, per se. And you have to look at the economic and when you look at the commercials in the US, Patrick, there is a call to action maybe, but it's quite light, but they must serve a purpose because they are spending so much money. So, there's got to be some data to suggest that they are adding some sort of commercial benefit, if I could say that.
You know, there's articles out in the US that say, you know, that first line for the pharmaceutical companies is the DTC and the second line is a rep so it's actually reversed over even before Covid-19. And I'm looking at Canada in the sense of, there are now more restrictions in terms of how we can communicate because of Covid-19.
Is this something that could be put on the agenda going forward? And it would be for companies that maybe want to explore this and say there's an opportunity in Canada to adjust or modify the guidelines and have something going that way.
And then that leads me to a segue, which is, Patrick, you're right. You know, a lot of people as soon as this happened, they started digitalising their materials, sending them back in. Now they're thinking, "Okay, I got to do some emailing of campaigns and see if I can get webinars going or this or that," And that's the tip of the iceberg, but in a virtual setting that we're in and this was a company I was with in the past, they were working with us commercially to try and build a relationship with the doctor to get the doctor's personal email address. So not just the clinic, you know, like send it to Millstreet Clinic and info at and then you know, the receptionist would send maybe the message off to the doctors in the clinic if there were five or 10 doctors but to actually have the personal email of the doctor or his business email but an email that goes directly to his inbox. And the idea there was for products that were coming off patent two years in advance, you would want to sort of shift resources off those products, let's say sales reps, and start doing a digital campaign to remind the doctor of the product.
And so, this was way before Covid-19. But in this Covid-19 area, I can see that if reps want to have a dialogue with the doctors, it's going to start by trying to get that personal email address. And I'm sure if you go to any CRM system that any company has, they might have an email address field, but I'm sure it's blank. Or it's just got the clinic email info at Mill Street clinic or something like this. And so that's another challenge. I guess going forward for PAAB because I could see companies trying to say "Hey, if you can't go see them in person, how are you developing a dialogue in relationship with this doctor?"
So what do you see on that, Patrick? What's the rule for PAAB in that new channel of engagement?
It's neither challenge nor new role. At the end of the day, it's still a commercial electronic message, whether or not I'm sending it to your private email or I'm sending it to your clinic email. If I'm sending Dr. Johnson and Dr. Vee and Dr. Miranda or whatever, the same email and it's their personal emails, guess what it's advertising promotional systems, it's subject to the advertising regulations. So that doesn't, really doesn't change anything.
We're completely uninterested and oblivious to whether or not is going to an individual or through the clinic, an electronic message that promotes the sale of a product is subject to advertising. It's subject to the PAAB code. In fact, we had a complaint about that very matter last year. It was an email, it's just it was sent to 15 doctors personal emails, the company and it was a rather large company was completely surprised that this is something that required PAAB review that this was something that was subject to advertising standards, it was lacking their balance. There were key distinct Food and Drug Act issues with email. Sending a personal email to a group of individuals and calling it personal. I'm using air quotation marks. This is a podcast, I just realized that. I gotta. I gotta disclose that.
In fact, that doesn't change anything. You always have to go back to Health Canada's policy document on the distinction between advertising and other activities. You ask yourself, "Is this subject to advertising regulations?" And you always have to pause and kind of think about that.
What's the challenge here is people when they perceive that they're doing something new, they've got to kind of go back to those first principles and say, "Even though I don't think this is subject to advertising provisions, is it?" Let's actually pause and think about that for a second. What's my intention? What is it that I'm doing? Am I sending this to one individual in response to an unsolicited request? Well, yes, that would not be subject to advertising, but just about everything else, unprompted emails, regardless of which email address I'm sending it to. It's subject to advertising regulations.
It doesn't make it good or bad, keep that in mind. I'm not saying don't do that. That's okay. If you've got permission to send it to somebody, email. I mean, go to it. But yeah, this is still subject to advertising regulations and the challenge, I would say is making sure people understand that.
Yeah, I agree with you, Patrick. I visualize probably from a commercial standpoint, and this is just in theory, if I had all my reps being able to communicate to their doctors on their emails, part of it is probably advertising and promotion where I agree with you, they would have to use the tools that are approved in their communications.
But the other part of it is just the dialogue, which isn't part of the approval, but I believe that's a direction you're going to have to try and get to and in order to build that you have to have value added to the doctor or to the clinic or to the patient, but that's a theme that's going to have to happen which will be a blend between just trying to add value and ensuring that you're within the scope of the practices.
You raised a fantastic point there, because a year ago or last year, you'd have your typical conversation with a physician, right? And a key criticism that non industry viewers on the system, you have these advertising, promotional systems, these materials, they go through pre-clearance, but nobody's controlling what the rep is actually saying.
But the key there is it's said, it disappears. Right? So there's, industry is always kind of been able to say, "I don't have any evidence that this has been said and you know, what if it has, we certainly changed training accordingly." Now when you're talking about messages that are written, that are documented, that go back and forth, and there's a record of I would advise industry to be very cautious about how you're training reps in that engagement.
Engagements important, dialogue is important. But you got to keep in mind now now there's a record and it's a record on certainly your side, it's a record on the physician side as well. And somebody now has the basis for a complaint. In the past, if somebody was say, "Hey, I was told X, Y and Z, I don't think, I think that's off label, or I think that's inappropriate because of X, Y and Z." Okay, well, what can I do? That's one person telling me something was said, someone else is saying something different. Now there's a record.
So, I would advise you to be very cautious there. And that's part of the reason why I think we've seen a surge in email templates. So, what we do is we approve the template with certain variable fields to enable that segmentation or that personalization, right, so that the reps not freely typing whatever the heck they want. Now, there are some elements where you do need to have "Hey. Sorry I missed you the other day." Well, you wouldn't be saying sorry, I missed you the other day because I never tried to see the other day but you get the point. There are some free open text elements where we can be very deliberate. About make sure your rep is sticking to X, Y and Z make sure they're only talking about these transactional details and not the product or the disease in these specific points or areas.
Our preclearance of emails has kind of elaborated given that reality and I advise people to go that route as opposed to, "Don't worry about it, just write your stuff the Dr. So-and-so." A: will your medical and regulatory departments be okay with that to begin with, because, and your legal department specifically, because you're taking on immense legal risks becuase there is now documented record, and B: that's technically not preclearance. That's not adherence to the Canadian system that's been put in place to help protect self regulation.
And some people view preclearance as kind of this thing I have to do sometimes, and if I've got a way to get around it then, groovy, let's do that. That's actually a protective mechanism and it's not so much that people want to mislead, but we're here to protect you from your wishful thinking. That's the way I kind of view it, so yeah, take advantage of that mechanism. Don't try to find ways to go around it. You're just hurting yourself in the long run.
Great thoughts today from Mike and Patrick, I like the point here is we got a new approach, new digital ideas but it's all new training.
You've been listening to the NPC podcast. I'm your host Peter Brenders.
Joining us today was Mike Egli, Canadian General Manager from Aspen Pharmacare Canada Inc and Patrick Massad, the Commissioner from the Pharmaceutical Advertising Advisory Board.
Thank you for listening
Thanks to Mike and Patrick and Peter for that lively exchange.
We’ll keep the conversation going about DTC in the months ago. We may have to wait to see what direct to consumer campaigns might look like in Canada, but there’s something you can get right now that’s direct: that’s this podcast.
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