Healthcare marketers are adjusting to shifting expectations

Healthcare marketing is evolving in the face of potential new regulations, budding technology, and new modes of advertising.

In what could be the most consequential change, President Donald Trump last September issued a memorandum directing the Department of Health and Human Services (HHS) to get rid of what’s known as the “adequate provision” loophole. It allows pharma companies to summarize safety and risk information in TV ads, directing consumers to other sources, such as a website, to get the full information on a medicine.

The FDA, which is part of HHS, is expected to file a formal proposed rule that eliminates the loophole in December.

Getting rid of the provision would shake up pharma advertising, as companies would have to disclose all of a drug’s risks and contraindications directly, in typically short, 30- to 60-second ads. Longer spots are more expensive and pharma companies already spend billions on marketing. The pharma industry spent a combined $6 billion per year on direct-to-consumer advertising from 2016 to 2018, according to the Government Accountability Office.

Beyond potential regulatory changes, healthcare in recent years has been challenged to embrace new advertising channels, such as social media and online video.

Healthcare Brew sat down with Mario Muredda, global CEO of marketing agency Ogilvy Health, to talk about how the agency is responding to such challenges. Ogilvy is owned by WPP, one of the largest ad agencies in the world based on revenue. Its health division works with big-name pharma companies in addition to hospitals, government health agencies, digital health companies, and more.

This interview has been lightly edited for length and clarity.

What are the biggest challenges you’re facing right now as a healthcare marketing agency?

There’s always uncertainty in a highly regulated environment, in particular when governments change over. Whenever there’s a change in party, all of us and our clients wonder what might the impact of that change be on us as an industry in terms of regulations, in terms of path to approvals.

We’re also talking to consumers and patients more and more often. The challenge there is, it’s a shift in the industry in terms of how to think beyond the healthcare provider and the nurse and the hospital system to really think more inclusively, including the patient, the caregiver, and everyone around them. Agencies that don’t embrace patients, consumers, and caregivers are learning to adapt to that.

Are you taking any steps at Ogilvy Health to prepare for the possibility of the FDA getting rid of the adequate provision loophole?

A lot of it is wait and see. We scenario-plan what it might look like and what the impact might be to how we communicate, and so we’re prepared for what that could look like if the eventualities that we’re expecting happen. We’re ready to pivot around what [HHS] says is the best thing to do.

What it means is we have to figure out, if we do TV, how might that spot change to accommodate a changing requirement for fair balance. There’s an upper limit to how long a spot can be on television, and so it might change the marketing mix at the end of the day, and we’re prepared for that. It might change the duration of a spot. It might change the channel preference that we work on with our clients as well, and we’re open for all of those eventualities. I think what we’re all hungry for is direction. We’re ready, tell us what that direction is so we can make sure that we’re being compliant.

You said healthcare brands are now behaving more and more like consumer brands and talking directly to patients. Why is that?

What our industry is recognizing is we have to think about people with conditions and diseases as consumers of information and consumers of health.

The first major brand to talk about a cancer condition on TV was Bristol Myers Squibb’s Opdivo (2015). Before some of those TV spots ran, you would never have seen a commercial for a cancer drug on television. The thinking there was that we only talk to doctors about this condition, we don’t talk to patients and consumers about it. What we realized is, only talking to the doctor side of the equation is making it really hard for people suffering with these conditions to learn about their conditions, to ask better questions about how to be treated, and to really take control of their health journey in their hands. And so we’re seeing that shift across all different therapeutic categories now.

If you look at TV spend by pharma brands over the last 10 to 12 years, you’ll see a really steep curve…and that is a direct reflection of wanting to talk to patients and consumers rather than just physicians.

Are you using technologies like AI to adapt to the changing landscape?

Because we’re part of WPP, we share with our parent company and our siblings an AI-based operating system called WPP Open. It’s not replacing people, it’s making the people who work here much more efficient, and it’s giving us different ways to think about the work we’re doing.

An example of something we can do with the platform: We decided to build a tool in WPP Open [called Ria] that leverages our 30+ years of experience at Ogilvy Health plus all of the regulatory guidance that has ever been issued by the FDA’s Office of Prescription Drug Promotion. We created an agent that allows us to evaluate all of our work in real time relative to the guidelines that exist. Not just the guidelines that have been published at various intervals over time, but it’s updated with any regulatory guidance that comes out from the FDA in real time. So we have this living, breathing agent that we use to evaluate all our work as we’re developing it. In real time, we can input any creative or any writing that we’re generating for a specific therapeutic category or product and ensure that we’re doing so in a way that is compliant with all of the most up-to-date regulations.