Pandemic working conditions can alter your timeframes in unpredictable ways. Some timeframes may grow shorter, as reviewers have more time at home to identify mistakes they deem impactful and needing immediate attention; in other cases, your processes may grow prolonged due to a lack of interpersonal communication altering team dynamics. How can you keep performance constant during a time of so much change?
- Recognize that the lack of in-person interaction can cut down on once-typical reminders and updates, leading to more requests for help
- Compensate for the decline in casual guidance that had once made the review process easier
- Preserve dedicated review time to avoid the growth of multiple meetings
Working remotely is particularly challenging for your sales reps, who now may not be able to see everyone receiving a group-based pitch and may struggle in gathering and responding to questions afterwards. PRCs can help them by setting and overseeing new standards for interacting with virtual audiences.
- Construct additional operational messaging while making sure the PI is always available
- Look through novel methods for preparation and follow-ups
- Account for changes in the immediate relevance of certain messaging aspects
AI can serve a valuable editing function, checking for basics against a set of approved claims and appropriate balance, and thus freeing up reviewers so they can focus on larger claims and risks. Large pharma is already moving the resources and technology for this into place, but it will take time to properly implement and regularly maintain.
- Build or buy AI programs that can recognize substantiated and well-referenced claims based on your past usage
- Gauge the possibilities for rapid data crawls, text changes, and reference updates
- Compare outsourced AI options that can serve as bolt-ons to your core claims documents
Message space on social media can be so limited as to make it very difficult to make all the needed information fit; depending on the platform, the importance of favoring safety data can make it challenging to find space for marketers to push more positive aspects. The industry has been struggling with these questions for nearly a decade – how much closer are you and your peers to truly finding best practice?
- Review cases where changes to layout, multimedia features, or drop-down menus, among others, caused problems or disagreement
- Establish if separate review channels are required for social media
- Grapple with the implications of newer digital media such as podcasts, which may be in a gray area between advertisements and media broadcasts
Normally, product launches would involve daily PRC meetings with intense cooperation; this atmosphere is particularly hard to capture online. By facing logistical challenges up-front, your team can prepare for them and do their best to replicate the most productive session formats.
- Outline and rearrange the time required for cross-disciplinary sign-off on an entire upcoming campaign’s materials
- Use virtual breakout rooms to compensate for the lack of small group networking
- Emphasize regular and clear communication with commercial team members as they prepare their SWOT analysis
The materials you display at a virtual symposium or booth can have a long-lasting viewable life, and – unlike your website or social media – their dissemination and withdrawal are not entirely under your control. If there are subsequent changes to product labels or indications, how can you remove older materials from virtual circulation?
- Recognize that virtual and hybrid congresses will remain a factor even after in-person meetings resume
- Outline the most critical questions for access and compliance in virtual materials
- Update your sales rep training techniques as they transition to virtual booths
Interactivity is the whole point of social media – but it brings added risk. If your social media feed receives public reports of adverse events, you must have a process in place for expedited review within 24 hours. Is your team capable of working that quickly, and if not, should you re-examine your social media presence?
- Explore the utility of digital platforms if open commenting becomes too problematic
- Brainstorm the necessary oversight and priorities that allow for rapid response
- Anticipate a future in which nearly the entire patient population has grown up discussing healthcare choices on social media – and plan accordingly
- Specify the global reach of your social media campaigns and the international regulatory agencies that may be involved in observing the public comments you receive
FDA will challenge you to justify your focus on particular claims being consistent with labels, and with the proper strategy you may be able to speed up the label negotiation process. Your label strategy should not be driven by marketers; rather, medical team members should specify allowable information.
- Prioritize this during training of new team members
- Broaden the variety of published materials that remain consistent with labeling
- Track how different companies have promoted primary and secondary endpoints
- Seek advisory comment on CFL data
4 out of 5 OPDP warning letters relate to either omitting or downplaying risk information. Ad agencies may try to push the envelope on this – presenting risk information in a subdued manner, or after a signature block – and moves like that put you at risk.
- Focus on marketing techniques that have triggered OPDP intervention, including suggesting that readers seek safety data elsewhere or continue reading after the apparent end of the piece
- Consider ways to maintain fair balance in character-limited promotional pieces
- Emphasize that risk information must be visually the same as the rest of the piece
Even if OPDP letters are heavily redacted, they can still provide valuable clues if you know where to look. A growing trend is for letters to refer back to prior advisory comments to the recipient company. Can you quantify how often OPDP looks back at their past warnings, and whether this influences their later judgments and penalties?
- Drill down into the prevalence of commentary regarding prior communications
- Track the sequence and severity of OPDP comments across multiple rounds
- Examine whether initial OPDP feedback results in heightened expectations and harsher penalties
After many years of preparation, submitting promotional materials to OPDP via the e2253 portal will finally become mandatory in June 2021. What have been the most important lessons from your pilot projects, and what final issues remain unresolved?
- Determine the need for bringing regulatory publishing in-house to accommodate online submissions
- Find ideal external regulatory publishing vendors
- Spotlight how the reality of this portal process has differed from expectations
Who makes the training materials you use for new PRC team members, and who takes the lead in delivering them? Training methodologies should help empower new staff to be creative, while at the same time providing a detailed brand portal for claims management that makes it less likely new members will wind up re-fighting battles that had been settled years ago.
- Prioritize solution-oriented negotiation skills
- Construct mentoring and shadowing programs that provide key resources
- Acknowledge the unique risks of onboarding and turnover around launch timeframes
- Evaluate dedicated training courses
Around major milestones in the product life cycle or the launch of a competitor, there may be hundreds of items per reviewer per month.Reviewers can naturally feel behind and overwhelmed, especially if they are working in pandemic conditions not fully under their control and different than how they were trained.How do you get better inputs in planning, especially for lean times or peak cycles?
- Spotlight the types of pieces that will always take priority
- Devote more time to “central” documents, then check derivatives for consistency
- Evaluate if more days can be added to the review cycle
Whether two biopharma companies are in a true 50:50 partnership on co-developing and co-marketing one drug, or one company is acquiring the assets and staff of the other, PRC leaders need to carefully map out future changes in their team roster and functions. Changing system access rights and onboarding methods are only some of the new tools that must be at your disposal if a collaboration is to succeed.
Compare and contrast the leadership strategies that work best in partnerships and M&As
Emphasize flexibility for incorporating processes from new partners if they turn out to work better
Retain the employees most essential for newly-acquired products
Well-trained publishing and marketing operations team members can help you narrow down the most efficient PRC methods. A firmer emphasis on operations can help take the “churn” out of reviews and noticeably benefit your timelines.
- Discuss why regulatory publishing serves as a critical PRC component
- Highlight how partnerships with operations can help with compliance and efficiency
- Review pilot projects that gauged PRC performance
The strength and the challenge for PRCs is that they gather expertise across multiple business functions and disciplines. With such diverse backgrounds, it can be difficult to properly set expectations and to make sure all colleagues fully recognize what a PRC can and cannot do; if they overburden it with substandard inputs or a glut of emergency requests, it will struggle. Through improved outreach and training, PRC managers can achieve goal-oriented improvements in efficiency and significantly reduce overload risks.
- 2021-03-24Clearly communicate the need for volume caps
- Walk your colleagues through what works and what doesn’t in expedited requests
- Emphasize the criteria for content-readiness
How long should your PRC debate before it becomes clear that upper managers must get involved? And how many levels of escalation should there be? There comes a point where it is no longer helpful to cycle repeatedly around the same topic, but for the sake of maintaining long-term PRC teamwork it is essential that the review elevation process not seem punitive or menacing.
- Rule out putting reviewers into adversarial positions
- Establish governance that gets the “churn” out of PRCs quickly
- Prepare leadership to make decisions on issues of risk that had caused discomfort
Expanding your editorial team can bring new value to your PRC, as their detail-oriented approach can ward off mistakes that hurt your credibility. Editors can be particularly helpful in maintaining consistency of messaging while working with multiple advertising agencies.
- Map out global review processes that send materials through different reviewers or marketing agencies but the same editors
- Rely on editors to remember comments and developments across different teams
- Formalize a process that keeps all input to agencies consistent
It’s very frustrating for PRCs to be brought into the process too late – when they first see a project that the submitter considers to be final but that actually requires extensive edits. More structured communication about the motive and audience for each promotional concept can help other departments recognize you as a collective part of their team, rather than a reviewer who signs off at the end.
- Walk marketing colleagues through the expected review timelines built into your system
- Gently correct the expectation that every group will be your highest priority for “rush jobs”
- Maintain what worked with daily team communication even when working remotely
Digital asset libraries are a tool that organizations can adopt to store, track and measure the usage of all files that encompass their brands’ creative output and intellectual property. These assets form a static repository, tracking all licenses and IP, while providing teams with a single source to help streamline content creation and re-use. Creating and managing a robust digital library is essential to streamlining material and review.
- Build out brand portals with all IP and assets to leverage throughout your organization
- Leverage existing processes to help populate the library and regulate asset usage more closely
- Establish clear paths of responsibility and oversight through training and change management initiatives
If marketing and medical professionals aren’t pushing boundaries, they aren’t doing their jobs; however, it is the PRC’s job to keep things realistic, grounding discussion around what has actually been done instead of expanded claims on what potentially could be. If reviewers are perceived as only rejecting new ideas, it can cause commercial tension – so instead prioritize the areas for agreement.
Cultivate a collaborative approach and avoid adversarial relationships
Convey what is possible without bluntly saying “no”
Recognize and benefit from creativity and commercial drive
