Case study: Achieving high standards in pharmaceutical marketing at CommonHealth
Marketing of pharmaceutical products is a potentially sensitive area and one that is highly regulated. It is important that all marketing reaches high ethical standards and puts the interests of patients first.
WPP company CommonHealth specialises in healthcare communications, including marketing pharmaceutical products to healthcare professionals through journal and online advertising and materials used by sales representatives when visiting doctors. CommonHealth creates TV, radio, and print advertising, and develops websites that promote pharmaceutical products directly to consumers. This marketing can play a useful role in providing up-to-date information on new medicines to doctors and patients.
CommonHealth is committed to achieving high ethical standards and compliance with all relevant regulations. This means ensuring that all its work for clients is based on the following principles:
- Sound science – all claims made must be supported by valid scientific data.
- Fair balance – marketing must include information on product risks, as well as benefits.
Employees are expected to understand and comply with regulatory requirements, industry codes of practice, and style guidelines for pharmaceutical marketing established by the Food and Drug Administration’s Division of Drug Marketing, Advertising and Communications (DDMAC) and by standards and industry organisations such as the Accreditation Council for Continuing Medical Education (ACCME), the Pharmaceutical Research and Manufacturers of America (PhRMA), PhRMA DTC, and the American Medical Association.
Employees complete online training each year explaining the WPP Code of Business Ethics and Right to Speak policy, which encourages employees to report suspected ethical breaches anonymously.
CommonHealth employs specialist medical directors with advanced degrees in health sciences to help copywriters and account teams understand the scientific research behind a particular product and its therapeutic category. This also helps to ensure that all claims are supported by valid scientific data.
All campaigns are subject to three stages of review: CommonHealth’s medical directors, editors and senior account managers; the client’s legal, medical and regulatory departments; and DDMAC.
Some areas of pharmaceutical marketing are subject to a particularly high level of scrutiny, for example corporate sponsorship of Continuing Medical Education (CME) programs. All physicians in the US are required by law to undergo regular training and many CME programs are supported by pharmaceutical companies.
It is very important that the financial support does not influence the course content. CommonHealth provides opportunities for its clients to sponsor CME programs by working with medical schools and other organisations that run the programs. Employees involved in this area must strictly adhere to ACCME and PhRMA standards that guide the development and execution of CME programs.