Published on February 27, 2014
Marketing in the Age of Obama
Disclaimer The views and opinions expressed in the following PowerPoint slides are those of the individual presenter and should not be attributed to Drug Information Association, Inc. (“DIA”), its directors, officers, employees, volunteers, members, chapters, councils, Special Interest Area Communities or affiliates, or any organization with which the presenter is employed or affiliated. These PowerPoint slides are the intellectual property of the individual presenter and are protected under the copyright laws of the United States of America and other countries. Used by permission. All rights reserved. Drug Information Association, DIA and DIA logo are registered trademarks or trademarks of Drug Information Association Inc. All other trademarks are the property of their respective owners. DIA www.diahome.org 2
Our Presenters Mukesh Mehta, PDR Network Christine Bradshaw, Porzio Life Sciences Dale Cooke, Digitas Health DIA www.diahome.org 3
Agenda • Legislative Landscape • ARRA & EHRs • FDASIA & ACA Sunshine & ACOs DIA www.diahome.org 4
A busy few years DIA www.diahome.org 5
And then the world changed Three pillars of Obamacare • No one can be denied coverage • Individuals must purchase coverage • Subsidies make insurance affordable DIA www.diahome.org 6
Marketing implications of Obamacare 1. Expanded pool of insured comprising: – Young, healthy people – People with preexisting conditions 2. Consistent coverage of basic care 3. Individuals more responsible for healthcare spending – “Cadillac” tax on health insurance – FSA changes DIA www.diahome.org 7
PCORI • Patient-Centered Outcomes Research Institute • Non-profit institute established to conduct comparative effectiveness research DIA www.diahome.org 8
Sample PCORI Project: BioScreen for MS “BioScreen was originally designed for researchers and physicians. But with the Patient-Centered Outcomes Research Institute (PCORI) Pilot Project funding, the UCSF team is converting the tool into an accessible source of information for patients to use with guidance from their clinicians. Input from community members with expertise in emerging technologies and legal and administrative issues has helped the researchers create a secure digital portal to a library of up-to-date, anonymous clinical information. BioScreen is intended to improve care by fostering patients’ interactions with clinicians, self-reporting of clinical information, and compliance to treatment plans.” —From PCORI website, http://www.pcori.org/funding-opportunities/pfa-awards/pilot-projects/pilot-program-featured-page-hauser-2/ DIA www.diahome.org 9
Sample PCORI Pilot Project DIA www.diahome.org 10
Sample PCORI Pilot Project Video available at http://www.youtube.com/watch?v=BFAzIYwx adU#t=10 DIA www.diahome.org 11
FDASIA FDASIA required FDA to issue social media guidance by August 1, 2014 http://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/UCM381352.pdf DIA www.diahome.org 12
But wait there’s more… DIA www.diahome.org 13
What are postmarketing submissions? The guidance addresses two questions about the 2253 submission: 1. Whether to submit materials 2. What to submit DIA www.diahome.org 14
Determining whether to submit Three sets of circumstances: 1. Sites “owned, controlled, created, influenced, or operated by, or on behalf of the firm…. even if the influence is limited.”* 2. Site pages if the firm “influenced the placement” of promotional materials.** 3. When agents or employees are “acting on behalf of the firm”** * Postmarketing Guidance, page 3. ** Postmarketing Guidance, page 4. DIA www.diahome.org 15
What to submit 1. For static materials with interactive components, submit static and indicate what changes (e.g., which portion of the website houses an online discussion forum) 2. For third-party sites, submit static elements with first communication (e.g., first Tweet & Twitter profile page). 3. Submit a monthly listing of locations (URLs) with real-time discussion. DIA www.diahome.org 16
30-day submissions Publicly accessible discussions > Submit a list of URLs where real-time discussions are happening > Update the list every 30 days (confirming, adding, or removing as necessary) to reflect current involvement > Do NOT submit the actual interactions themselves Not publicly accessible discussions (e.g., behind a log-in) > Submit a list of URLs where real-time discussions are happening > Update the list every 30 days (confirming, adding, or removing as necessary) to reflect current involvement > Submit screenshots or other representations of the actual interactions themselves > Indicate what discussion sponsor owns > Provide enough context for FDA to understand/evaluate the discussion DIA www.diahome.org 17
Open questions 1. What constitutes being publicly accessible? a) If you have to “like” a page to view it, is it publicly accessible? 2. Does this open up or limit the activities of employees? a) Do companies now have to submit the URL of every employee who mentions a product on their Twitter, Facebook, Tumblr, Pinterest, etc.? 3. Are companies responsible for sites where they advertise? DIA www.diahome.org 18
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