The lore of pharma advertising is littered with stories of nightmarish regulatory battles. The vise-like grip of the law is enough to turn the most placid personalities into raging beasts, in a kind of evolution only a Pokémon fanatic could love.
Really, I sympathize. In a situation where the FDA allows no superiority claims in the absence of a head-to-head trial, the temptation for manufacturers to gussy-up their products with statistical manipulation is irresistible. Trouble is, the strict regulatory and legal requirements that govern every word and image make transmitting a coherent marketing message devilishly difficult.
That’s not to say, however, that the only response is to fold your arms and crank out drivel. I get it, you want to play it safe and not incur any Guidance from your legal-regulatory team. And doing anything else requires an Account Director to occasionally say “No” to your client.
But maybe the only way out of the nightmare is to confront it head on.
Instead of hedging, second guessing and, frankly, cowering before internal regulators, pharma brand managers should engage them directly. With the help of an agency creative team, they should work out a coherent messaging strategy in advance that’s both approvable and, just as important, engaging.
It’s a process that requires continued vigilance, yet it’s frequently side-stepped by establishing a rigid dichotomy between Copy (facts) and Graphics (visual metaphors). Over time, all manner of garish imagery has served as eye-candy, expressly to distract people from a dry rehash of the clinical trial data.
These executions range all over the spectrum but the middle ground is inhabited by:
When directed to HCPs, the copy merely stacks claims on top of graphs, charts and tables until the pamphlet runs out of space. When the audience is consumers, boilerplate small talk bleats “it’s natural to be afraid,” then strings generalities together about drug and disease until the designers run out of stock art. What you end up with, especially on the consumer side, often differs little from the information available at some combination of WebMD, Mayoclinic.org and Drugs.com
In fact, if you’ve ever been tasked to “refresh” pharma Web site copy, you know how much of the copy provided by the previous agency was picked up nearly verbatim from these, or similar sites. Worse, copywriters are perennially asked where their copy “comes from,” as if there were no such thing as writing an original text, based on the direct consultation of primary sources. Instead, one is often enjoined to copy the copy that someone in Copy copied before — as if the original writer were anything more than another harried person slamming words together to meet an impossible deadline.
And, hey, the result is an ad object, so why worry?
Yet the goal of the exercise is communication. Let me be the first to tell you that the two aren’t automatically the same thing. Pages covered with unassimilated facts are as incommunicative as blank pages. Whatever the target audience, people need to know what you mean your facts to convey. To achieve that takes a fine balance between imagination and planning. For the same reason that eating a piece of Black Forest cake is not equivalent to reading a list of its ingredients, your communication needs to be a rich and enriching experience. And that doesn’t happen by accident.
In other words, every communication must deliver value, which facts alone can’t do. But when presented in a way that enlightens, strengthens convictions, steels resolve and motivates people to action, those same facts are priceless.
Add value through partnership.
Trouble is, of course, that takes time. To accomplish the goals I’ve just laid out, you have to look up from your Approved Claims List and develop a set of over-arching messages that summarize, educate and, particularly for consumers, show a way forward. And that’s where the partnership with your regulatory team becomes crucial. Because, in case you haven’t noticed, waiting until the actual review to present your idea for a compelling brand narrative always fails miserably.
Instead, start the process by working out acceptable thematic messages with Regulatory that rise above the level of:
“In a clinical trial, Brand W improved Factor X by Y% in Month Z.”
Just as important, realize that forming this partnership does not diminish the role of either the Brand Manager or the Creative Director.
At the same time, it does diminish the head-banging, hair-pulling, weekend-crushing last-minute revisions that I suppose a small percentage of C-suite masochists must actually enjoy. Otherwise, I can’t account for the current passive acceptance of the status quo, which pitches talented people from at least three different disciplines into month after month of dreary siege warfare with common sense.