Martha Stewart, the FDA and the Era of Transparency

Posted by: Brian Reid in Healthcare Insights on July 29, 2010
Call them the “Martha Stewart Rules.”
In early 2002, a weekly newsletter called The Cancer Letter, published elements of a letter than the U.S. Food and Drug Administration had sent to ImClone, which was seeking to market its Erbitux cancer drug. The letter’s contents — which spelled out data shortcomings in exhaustive and technical detail — hadn’t previously been made public, and the bottom dropped out of ImClone’s stock. Insiders who had traded on the once-private information, including CEO Harlan Waksal and his friend Martha Stewart, ended up in jail. All because an FDA communication was kept secret.
Now, that may all be changing. The FDA, as part of a yearlong effort to be more transparent, in May released a series of 21 different proposals intended to make the agency’s actions clearer to consumers and stakeholders. Many of them are straightforward and commonsense: more information on recalls, better disclosure on inspections, and the like. But the one that may fundamentally change the way that the biopharma industry communications is “Draft Proposal 13,” in which the FDA’s transparency committee calls for the agency to not only announce when it decided not to approve a product (via a misleadingly titled “Complete Response Letter”), but detail the reasons for the decision.
This would be a massive change from the way business is currently conducted. While ImClone-level stonewalling isn’t standard, many companies take the view that the less said about regulatory setbacks, the better. Only rarely do companies actually release the text of their negative correspondence with the FDA.  If adopted, Draft Proposal 13 will fundamentally alter the way that companies talk about drugs that don’t sail through the FDA process. There will be no hiding: if additional studies are needed, that will be clear. If the agency is nervous about safety issues, that’ll be out there in black and white.
Fortunately, the best way to deal under the new rules will be exactly the same as the best way to deal with the old news. The more information that a company can provide, the better. Companies that can be as transparent with the FDA — if not more so — will earn the respect of the media, the trust of investors and the confidence of consumers. The only other option is to bet against the march toward transparency. That’s a dangerous path.
Just ask Martha.
By: Brian Reid

Brian Reid is a director at WCG in the product group, where he specializes in media. He is a former journalist who believes content really is king.

Find me on: Twitter

SlideShare new custom channel a must for business

Posted by: Bob Pearson in Social Media Insights & Trends on July 26, 2010

I’ve been impressed by how quickly SlideShare’s traffic has grown from 12MM unique visitors less than one year ago to 30MM unique visitors each month today.   That’s a lot of us looking for new insights and data.   What’s amazing is that we are at the beginning of where  this community is heading. 

In my view, SlideShare is one of the more important social media channels for today’s business.  It is one of the better places to learn and share information without a lot of noise.   It  has potential to become a solid location for investor relations professionals to share their latest information.  Increased use by IR, alone, will add tremendous value to this community.

It’s time for all businesses to consider SlideShare, whether it is a simple account or a new custom channel.   More info at  http://bit.ly/bIyqSU

 All the best, Bob

By: Bob Pearson

Chief Technology & Media Officer, WCG

Find me on: Twitter Facebook

Social Media Truisms – Someone else can do it for you

Posted by: Greg Matthews in Social Media Insights & Trends on July 26, 2010

Social media in the enterprise is still in its infancy. As with any significant change in the way business is done, it’s filled with brilliance, innovation, exploration and “next practices.” But it’s also filled with red herrings, misunderstood causes and correlations, and snake oil salesmen. In this series, I’m taking a look at a series of social media “truisms” – the conventional wisdom of the day – and asking some questions about how universally true they really are.

Thanks for joining us previously as we explored truisms numbers one, two and three: The ChampionThe Strategy. and The “Me Too.” Today we’ll look at truism number four: The “Someone else can do it for you”

“For hire: Social Media intern to man twitter and facebook accounts.  Unpaid.”

Two years ago, it was pretty cool for a company to have a twitter account.  When Naimul, Chris and I introduced Humana’s first social media properties, we definitely thought that we were livin’ on the edge (cue Aerosmith music).  But these days, what company doesn’t have a twitter account and a facebook page?  Even the stodgiest of companies is recognizing that there’s not much danger in tweeting out your press releases to the waiting world.  And most of the time, there’s an intern or PR agency cranking them out on behalf of the company.  And that’s a way to go, for sure.  As we examined in Monday’s “Me Too” post, there’s value in achieving parity … but there’s a lot MORE value in achieving parity if you’re doing it as a small step on the way to something else.

Last week Frank Eliason announced that he was leaving Comcast Cable, the company that he helped transform from a customer service mockery to a revered business case study.  For those of you who don’t know the story, I’ll give you the nutshell version here (you should really read Shel Israel’s Twitterville or Chris Brogan and Julien Smith’s Trust Agents to get the whole thing; they’re fun to read and full of great ideas).  It started with a YouTube video of a ComCast repairman who had fallen asleep on the couch of a customer.  Got a gajillion views, and exposed what the world already knew: Comcast’s had lousy customer service.  The social web was loaded with rants about the company – a search on google or twitter would generate hundreds (or even thousands) of customer complaints.  Enter customer service rep Frank.  He started a twitter account called ComcastCares, and started responded to them.  One by one.  And fixing customers’ problems.  The customers noticed, and started talking about it.  Next thing you know, Frank’s build a team of agents responding to service requests on the internet, and Comcast was the darling of the customer service world.

Did you miss the part about how Frank did that by tweeting out links to press releases?  [Tricked you! He didn't.]

There’s truly nothing wrong with tweeting press releases.  But couldn’t you do a little more?  How about going out to find people to follow who might be interested in your products?  How about listening to what kind of things they’re talking about – and who they’re talking to?  If you’re not prohibited from doing so (some industries have some pretty serious regulations governing their marketing activities), you might even reply to them.  When they ask a question (FYI: People ask a LOT of questions in social media; check out Yahoo Answers, Mahalo or LinkedIn Answers if you don’t believe me) that you know the answer to, maybe you could help them out by responding.  If there are people who write about your company or your industry, are you reading their news sites or blogs?  Commenting on them?  How about feeding them content that might be useful to them in their work – even if it doesn’t directly reference your company?

These are things that aren’t terribly difficult or risky to do – but they’re probably not do-able by an intern.  And if you have an unqualified person out there representing your brand, your risk does increase – perhaps exponentially.  I’m not pushing you to get out there and do something you’re uncomfortable with … not everyone is really that into geeking out with customers online.  But it doesn’t have to be you!  I wouldn’t be a bit surprised if there was someone in your sales and/or marketing and/or service and/or product development team that would LOVE to geek out with customers.  At my old company, Humana, we did a mini-survey on the intranet and found out that a) over 1,500 employees were professed bloggers and b) more than 10% of them were blogging about health or healthcare.  [Hmmmm!] If you can find a way to tap into that passion, you have a real chance to elevate the way your brand in the eyes of the people who care about it (or even better, the people who DON’T care about it today).

If you’re going to stick with (or get into) the press release tweeting business, feel free to grab an intern.  But if you’re ready to move to the next level, my advice to you is:

1. Talk to a pro who’ll help you get started (DISCLOSURE.  YOU PROBABLY FIGURED THIS OUT ALREADY, BUT MY COMPANY AND I GET PAID TO DO THAT)

2. Find a way to tap into your existing employee base to see whether you have any Franks hidden away – I wouldn’t be a bit surprised if you did.

Has this worked for you?  Has it failed?  Do you have questions about how to make it work in reality?  What did I say in this post that was both dead wrong and stupid?  The comments belong to you – I’d love to hear from you.

And don’t forget to tune in next time for Trusim #5: “Regulated Industries Can’t Do Social”

To learn more about the inspiration for this series, check out the case study on Humana’s successful social media model, “The Town Square ” or this webinar from the RacePoint Group on Organizing for Social Media – where I was honored to present alongside Larry Weber and Steven Goldbach of the Monitor Group.

Intern Photo by adpowers

By: Greg Matthews

Greg Matthews is a Director in WCG’s interactive and social media team; formerly created and led Humana's community innovation and social media practice

Find me on: Twitter

The Five PR Moves that Helped the FDA ‘Win’ on Avandia

Posted by: Brian Reid in Healthcare Insights on July 22, 2010

It was tough calling winners and losers after last week’s 2-day marathon review of the diabetes medication Avandia by a U.S. Food and Drug Administration advisory committee. The final vote made clear that the drug was far from exonerated, but the complex nature of the recommendation (a majority voted to keep the drug on the market, with restrictions) handed critics of Avandia something less than a victory.

Still, there was no doubt that the FDA ended up in the “winner” column. The vote means that the agency has great latitude and scientific cover to shape the future of Avandia, and the FDA’s handling of the meeting won plaudits from both panelists (Tufts cardiologist Marvin Konstam said the meeting was proof that the FDA was working well: “I don’t think it’s been at all broken“) and the press (the Boston Herald said the FDA “deserves praise for letting staff members publicly debate the issues”.)

I don’t want to suggest that the success of the FDA was due to public relations, not science,  but FDA did make five PR moves that helped them successful manage the agency’s approach to the meeting:

1. FDA  got the data out early: The agency allowed the press to get a look at all of the materials that the panelists reviewer earlier than usual — accompanied by access to top FDA brass — which helped make the 700-odd pages of analysis more manageable. It would be tough to claim that the agency’s viewpoint was simple or that the FDA’s staff spoke with one voice, but the media had plenty of time to work it all out.

2. FDA brought out the big guns: I’ve attended somewhere nearing 100 panel meetings, and I’m not sure I’ve ever seen a cameo by the commissioner of the FDA. But Peggy Hamburg took the unusual step of addressing the panelists on the first day, making clear that the FDA expected a discussion around science, not hype or politics. That had a profound impact, and it made clear where the FDA stood on the process. As the RPM Report’s Ramsey Baghdadi put it: “Tone was perfect. Big time players make big time plays in big time games.”

3. FDA accepted contrarian viewpoints: Depending on your math, FDA officials had at least 5 different views on Avandia that were presented at the meeting. This kind of cacophony is counter to the keep-it-simple advice that we typically give when comes to messaging, but, in this case, it underscored a deeper FDA point: the agency was committed to scientific discourse. Period. And that was the message came through loud and clear in all coverage.

4. FDA respected the needs of the press: On the morning that the Avandia panel was to begin, the FDA was scheduled to release briefing documents for another high-profile meeting later in the week. Rather than hew to the usual schedule, which would have meant dropping the documents in the middle of key presentations on Avandia, the briefing information was disseminated in the pre-dawn hours. While brutal for night owls, the move recognized that the FDA press couldn’t do two things at once, and do them well.

5. FDA let the chips fall where they may: The other effect of not pushing a single unified view was that the agency didn’t appear to be influencing the panel in one way or another. That, in turn, allowed them to avoid one of the great perils of working too hard to disseminate a viewpoint: they never appeared controlling and never risked losing credibility as a result. Knowing how much control to give up is a subtle, dangerous game, but the FDA played it perfectly last week.

I’m hoping to incorporate a few of these lessons into my approach in the months and years to come. While some of the techniques should be standard practice, such as getting the press information quickly (#1) or respecting the complexity of the news cycle(#4), other FDA moves are certainty worth exploring, even if they carry some risk. Can we use top executives more strategically in roles they don’t usual fill (#2)? Can we endure contradictory messages if they help our audiences reach a deeper truth (#3)? The answers aren’t simple. But, then again, next practices rarely are.

(Disclosure: WCG has worked with GlaxoSmithKline on Avandia in the past, though we were not involved in this advisory committee in any way.)

It was tough calling winners and losers after last week’s 2-day marathon review of the diabetes medication Avandia by a U.S. Food and Drug Administration advisory committee. The final vote made clear that the drug was far from exonerated, but the complex nature of the recommendation (a majority voted to keep the drug on the market, with restrictions) handed critics of Avandia something less than a victory.


Still, there was no doubt that the FDA ended up in the “winner” column. The vote means that the agency has great latitude and scientific cover to shape the future of Avandia, and the FDA’s handling of the meeting won plaudits from both panelists (Tufts cardiologist Marvin Konstam said the meeting was proof that the FDA was working well. “I don’t think it’s been at all broken,” he said) and the press (the Boston Herald said the FDA “deserves praise for letting staff members publicly debate the issues”.)

I don’t want to suggest that the success of the FDA was due to public relations, not science,  but FDA did make five PR moves that helped them successful manage the agency’s approach to the meeting:

1. FDA  got the data out early: The agency allowed the press to get a look at all of the materials that the panelists reviewer earlier than usual — accompanied by access to top FDA brass — which helped make the 700-odd pages of analysis more manageable. It would be tough to claim that the agency’s viewpoint was simple or that the FDA’s staff spoke with one voice, but the media had plenty of time to work it all out.

2. FDA brought out the big guns: I’ve attended somewhere nearing 100 panel meetings, and I’m not sure I’ve ever seen a cameo by the commissioner of the FDA. But Peggy Hamburg took the unusual step of addressing the panelists on the first day, making clear that the FDA expected a discussion around science, not hype or politics. That had a profound impact, and it made clear where the FDA stood on the process. As RPM Report’s Ramsey Baghdadi put it: “Tone was perfect. Big time players make big time plays in big time games.” http://twitter.com/Ramsey_Baghdadi/status/18433140128
3. FDA accepted contrarian viewpoints: Depending on your math, FDA officials had at least 5 different views on Avandia that were presented at the meeting. This kind of cacophony is counter to the keep-it-simple advice that we typically give when comes to messaging, but, in this case, it underscored a deeper FDA point: the agency was committed to scientific discourse. Period. And that was the message came through loud and clear in all coverage.
4. FDA respected the needs of the press: On the morning that the Avandia panel was to begin, the FDA was scheduled to release briefing documents for another high-profile meeting later in the week. Rather than hew to the usual schedule, which would have meant dropping the documents in the middle of key presentations on Avandia. Instead, the briefing information was disseminated in the pre-dawn hours. While brutal for night owls, the move recognized that the FDA press couldn’t do two things at once, and do it well.
5. FDA let the chips fall where they may: The other effect of not pushing a single unified view was that the agency didn’t appear to be influencing the panel in one way or another. That, in turn, allowed them to avoid one of the great perils of working too hard to disseminate a viewpoint: they never appeared controlling and never risked losing credibility as a result. Knowing how much control to give up is a subtle, dangerous game, but the FDA played it perfectly last week.
I’m hoping to incorporate a few of these lessons into my approach in the months and years to come. While some of the techniques should be standard practice, such as getting the press information quickly (#1) or respecting the complexity of the news cycle(#4), other FDA moves are certainty worth exploring, even if they carry some risk. Can we use top executives more strategically in roles they don’t usual fill (#2)? Can we endure contradictory messages if they help our audiences reach a deeper truth (#3)? The answers aren’t simple. But, then again, next practices rarely are.
(Disclosure: WCG has worked with GlaxoSmithKline on Avandia in the past, though we were not involved in this advisory committee in any way.)
By: Brian Reid

Brian Reid is a director at WCG in the product group, where he specializes in media. He is a former journalist who believes content really is king.

Find me on: Twitter

Three Things Medical Device Companies Can Learn From Apple’s Averted “Antennagate” PR Crisis

Posted by: Scott Shadiow in Medical Device Dialogue, Social Media Insights & Trends on July 20, 2010

1.  Apple recognizes that every customer is important – and they make sure you know it.

In Steve Job’s brilliant press conference on the antenna issue in which he had the media absolutely eating out of his hand, http://ow.ly/2cHEk), he must have repeated the phrase that “every customer is important” as least a dozen times in different contexts. Even though the antenna issue only affected .055% of iPhone 4 users (making it NOT statistically significant for you p-value addicts out there), you couldn’t have walked away from the press conference without thinking, “Geez – Apple really cares about their customers.” What might have seemed like Steve Jobs just “talking” in a time of crisis wasn’t – in fact, it was just the opposite. Apple, who has always been very meticulous about what they give to their customers (as noted in the July issue of Fast Company: http://ow.ly/2dcOB), carefully crafted a message, no doubt product of thoroughly developed talking points and numerous rehearsals to make sure that above all else, Apple reassured customers and non-customers of their commitment to the end user.

Also on this point, medical device companies could do a better job of following Apple’s “every customer is important” mantra as we are in a unique position. We’re not just giving our patients a pill to take; we’re combining the best of both technology and healthcare to provide physicians and patients with an innovative solution. We have the opportunity to create a brand experience for our physician and patient customers that engages them and turns them into our ambassadors. If we recognize that every single patient is truly important AND actually treat them like they are, we can see what a great opportunity we have to create an ambassador army made up of every physician and patient customer with whom we interact.

2.  Apple identified what their customers were saying and what they wanted in a timely manner.

It took Apple only 22 days from the day that it shipped its new iPhone 4 to identify the antenna issue and proactively offer a solution (albeit some may think that this was at the behest of social media). 22 days is quicker than getting a piece of collateral through legal and regulatory review. How were they able to do this? Easy – they were listening! Yeah, yeah you say, but they are a tech company – of course they are listening online to what their customers are saying. I can guarantee you that there’s just as much being said about medical devices online that you don’t know about (but would care about) than there is about Apple’s “bumper.” You just have to know where to be looking and what to be listening for. So what’s your excuse not for listening? By engaging customers online and actively listening to what is being said about your brand, medical device manufacturers are able to identify issues proactively and not wait until issues spiral out of control. Best practices for effective brand management doesn’t just suggest active online listening…it demands it.

3.  Apple gave their customers what they wanted (this time)…and more.

So should medical device companies. I know not all medical device companies have Apple’s resources or their brand reputation. Few companies do and even fewer recognize how to use these effectively – however, whether you’re a small, VC-backed start up or the largest medical device company of the world, you need to give your customers what they want and then go beyond that by to give them even more – what they weren’t expecting. Too often today, we see companies relying solely on the value proposition of a given therapy to convince patients or physicians to choose their device. Medical device companies need to recognize that this is only 50% of the equation, especially in the crowded marketplace the device industry is becoming. What services do you offer? What added value do you bring to the physician? What experience do you give to patients? How do you improve the way they feel about your brand? This is what makes your customers choose your brand over your competition and it’s what keeps the Mac addicts coming back for more every time Apple puts out a new product.