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On Ethics, Transparency and Healthcare Public Relations
Recently, I have been having an ongoing public conversation with John Mack, author of the Pharma Marketing Blog, on the issue of healthcare public relations.  In his latest post he makes a number of points, including:  

-Non-branded healthcare public relations is not as regulated or transparent as other forms of educational promotion.  He argues:

“[T]here is undoubtedly a lot of PR activity – such as arranging press interviews with key opinion leaders, celebrities and patients – that is NOT reviewed internally.  These spokespersons do NOT have to provide fair balance.  They can say whatever pops into their heads and make the most outlandish endorsements with impunity.  In addition, when celebrity endorsers in the pay of pharma companies appear on TV interview shows, there is often no disclosure that they are being paid by the sponsor!”

-There are no guiding principles of direct-to-consumer (DTC) PR.  He asserts:

“Where is the PR industry’s ‘Guiding Principles of DTC PR Marketing?’  Are they under the desk?  Nope.  Not there!”

-We don’t know enough about the impact of dealings between the media and healthcare public relations professionals.  He observes:

[N]o reporter will write a favorable story because he/she was wined and dined at a press conference . . . What about taken out to a fancy dinner/  Golf outing? Significant other included?  How much does this goes on?  We don’t know . . .” Why Is This Topic Important? 

This conversation is critically important because of the changing nature of pharmaceutical marketing.  DTC advertising is under attack and the industry has adopted voluntary guidelines outlining how and when advertising to patients will occur.  As DTC advertising comes under increased scrutiny, it appears that pharmaceutical companies are turning to public relations to get their messages out.  According to a September 26, 2005 Advertising Age article, “PR Seems To Be The Rx To Get Around DTC Rules”:

“Several PR firms, who asked not to be identified because of their work for various drug makers, have confirmed that they have had discussions – ranging from ‘serious’ to ‘informal’ – about ramping up their efforts . . .”

In the same article, a public relations executive said:

“We’ve had some talks with our client about what to do in lieu of DTC . . . The companies are looking at broader ways of delivering a message.  I don’t think they are ‘skirting’ their DTC restrictions.

Yet, some critics of pharmaceutical marketing have charged that companies are using various public relations techniques to get around restrictions on DTC marketing.  Earlier this week, the lobbying group Consumers International said that common activities like sponsoring disease awareness campaigns and supporting patient advocates is not appropriate. 

Three Tough Questions & Answers About DTC PR

Some public relations professionals have recognized that regulators will likely start examining non-branded public relations activities more closely.  According to Ilyssa Levins, president of HCIL Consulting, a healthcare public relations and marketing firm:

“The FDA requirements are becoming more nuanced, and that means that as PR professionals, we need to be more careful and more thorough . . . It's important not just to be familiar enough with the new regulatory climate to stay out of trouble, but to understand it well enough to be able to work creatively, comfortably and effectively within it."

Levins is absolutely correct.  The regulatory environment is becoming more intense and public relations professionals have to recognize that “business as usual” will no longer cut it.  

Following are three questions and answers healthcare PR pros should be carefully considering.

Is It Appropriate For Pharmaceutical Companies To Engage In DTC PR?

Readers of this blog know that I believe it is very appropriate for pharmaceutical companies to engage in responsible promotion of their products.  Being responsible means providing patients and physicians with clear and actionable information about the risks and benefits of medications. 

As this era of consumer-driven healthcare becomes more entrenched, lay persons will have increasing and ultimate responsibility for deciding whether and how to use a pharmaceutical product or medical device.  Public relations can play an important role in providing patients with accurate information about conditions and products. 

Does Healthcare Public Relations Need A Set Of Guiding Principles? 

The Public Relations Society Of America (PRSA) has adopted a code of ethics that loosely regulates the activities of members.  I say loosely because PRSA no longer enforces the guidelines, but simply educates on them and removes members from the organization if they are in violation. 

Given the increased scrutiny of public relations, it is a good idea for the profession to adopt a comprehensive set of ethics guidelines.  The code could provide valuable guidance about how PR pros should work with the media, third-party organizations, physicians and others.  PhRMA’s guidelines on DTC advertising are a good place to start, as they are being widely adopted by the industry. 

How Can DTC Public Relations Become More Transparent?

Some have said that increased government regulation is the key to ensuring that DTC PR is more transparent and accountable.  There is merit to this argument, but currently the Food and Drug Administration’s Division of Drug Marketing, Advertising and Communications (DDMAC) is woefully understaffed.  In 2005, the agency reported that it had only 35 staff members to monitor more than 50,000 promotional items.

Clearly, the path to increased transparency involves developing a healthcare-specific set of guidelines that both the public relations and pharmaceutical industries agree on. 

That’s my take.  What’s your opinion?

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