Topic7: Coordinating MA and Commercial

A reader asks:  “Given the importance of consistent communication to the healthcare community, my company is seeking to better coordinate commercial and MA messaging.  What is the best approach for doing this?”

Thanks for the question.   The answer is: Very Carefully!  My sense is that your commercial function is driving this requirement.  I infer this from your question because you use the term “messaging” which is generally a marketing term.  Let’s remember that the purpose of marketing is promotional – promoting the sale and safe use of our products.  Since it is promotional, their communications are limited to on-label information.  If their communications go beyond the label, they are promoting off-label.  We all know this is against the law.

MA is allowed to discuss off label topics only under very specific circumstances – when they receive an unsolicited request.  MA is allowed to have some proactive discussions which are educational and non-promotional about related non-label topics depending on the rules of each organization.  See a detailed discussion of this here.

So, marketing is promotional and MA is non-promotional.  What “messaging” can a promotional and non-promotional functions share?  Conservative organizations would argue that any messaging topics that support the promotional needs of commercial is, by definition, not an acceptable topic for non-promotional MA.  But, many organizations would agree that promotional topics can focus on the product and its competitive positioning; while there can be related non-promotional topics such as the underlying disease state.

Most organizations that allow some coordination between promotional and non-promotional topics understand that this is a risk.  To avoid the risk of MA appearing as a promotional entity, most companies expect the coordination will go one way only:  from MA to commercial.  The theory is that MA is going to be educating the market regardless and the commercial function is just becoming aware of what MA is doing.

Going the other way, from commercial to MA, runs the risk of appearing as though MA is part of the promotional machinery.



So, reader, be careful.  Processes and systems must be put in place to ensure that the coordination is going the right way only.  Otherwise, you run the risk of a future whistleblower pulling out a document showing that MA has become a promotional resource.

For example, there need to be clear firewalls between the way MA is measured and the way commercial is measured on the effectiveness of their communication efforts.  We have discussed MA measurements here.  Commercial measures of effectiveness should be much more related to sales and penetration.

Thanks for the question!

If you have a question, please email me or leave it in the comments!