has captured our attention and spurred us into action.
Are Pharma Companies Ready for Click-To-Chat?
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Consumers today want information at their fingertips; they do not want to hunt for information that is buried within a website and many do not want to pick up a phone and call somebody. This is where Click-To-Chat (CTC) fits in. If a consumer is struggling to find a specific piece of information, rather than wasting time aimlessly searching or waiting on hold, they can have exactly what they are looking for within seconds. By using this form of Web-based communication, a person can click for immediate communication with another person in real time and potentially have answers to unanswered questions.
The recent FDA guidance on social media does not explicitly state that it applies to CTC, but it would seem that CTC falls into the category of promotional media because it is considered a “modern tool[s]…that often allow[s] for real-time communications and interactions that firms use to promote their drugs.” Before the FDA released this guidance, pharma companies were hesitant to pursue CTC functionality for fear of not being able to control or regulate what users are saying. Knowing that the FDA will be looking at promotional media under a microscope does not bode well for CTC in pharma; out of 85 of the top drugs with branded consumer websites, there are only two drug brands that feature CTC on their websites, ORENCIA (RA) and HERCEPTIN (breast cancer).
The initial implication of CTC being considered promotional media is that all CTC records will have to be submitted to the FDA with a 2253 form on a monthly basis. When submitting to the FDA, pharma companies will have to decide if their medical, legal, and regulatory (MLR) teams will also want to review each month’s materials, which would add a significant amount of work for already swamped MLR teams. Are pharmaceutical companies going to want to continue to pave the way for CTC by providing this modern tool even if it means sacrificing a degree of personalization for scripted responses to compromise with FDA guidelines?
If pharma companies are not willing to risk on this hefty investment, one alternative for entering into the CTC space is through HCPs. Instead of answering any range of questions that patients may have, that are more likely to include adverse events; CTC for HCPs can answer HCP’s questions, which are much more likely to be about drug mechanism of action, drug interactions, and clinical trial data. Pharma companies will still have to deal with monthly 2253 submissions, but the opportunity to modernize communication on the HCP side of the pharma industry could be enough persuasion to trek forward.
 “Guidance for Industry Fulfilling Regulatory Requirements for Postmarketing Submissions of Interactive Promotional Media for Prescription Human and Animal Drugs and Biologics.” FDA.gov. N.p., Jan. 2014. Web.