The U.S. Department of Health and Human Services recently announced a new rule that will mandate pharmaceutical companies to include the list price – the Wholesale Acquisition Cost – in direct-to-consumer television advertisements for prescription pharmaceuticals covered by Medicare or Medicaid if that list price is equal to or greater than $35 for a month’s supply or the usual course of therapy
Tracy Blackwell, a member of the leadership team at Fingerpaint’s New Jersey office, weighed in on what impact this new rule will have for marketers in the pharma space.
How will this impact pharma marketers?
Blackwell: HHS forcing drug manufacturers to include pricing on direct-to-consumer promotion will certainly have a big impact on pharma marketers. And, while the government and critics of the industry may suggest that this is because they fear transparency, we believe the reality is a bit more complicated. Some pharma marketers have gotten a jump on transparency.
Take Lilly as an example—a great example at that. Lilly launched the first TV spot with pricing info (for Trulicity) directing viewers to the website lillypricinginfo.com, as well as offering a toll-free number that ensures people can easily get a sense of what their medicines might cost them depending on the type of insurance they have. They also connect them with financial support. This is clearly an example of what “good” looks like—from a health literacy and information perspective. They’re being proactive and taking responsibility for creating an open, honest dialogue with patients and families.
The logistics and cost of such an effort are not small. Still, as members of the PhRMA committed in October, pharma marketers also want people to understand what medicine costs and how they can help people to afford the treatments they need, so they intend to provide this information to the public.
Beyond that, it wouldn’t be surprising if we see more unbranded campaigns that focus on educating the public versus promoting particular brands.
What’s the most important thing pharma marketers need to consider when complying with this new regulation?
Blackwell: Health literacy is probably the most important thing pharma marketers need to consider when developing their game plan for compliance with the new law. There are many important considerations for patients and families when starting a new medication. How does this medicine work? Are there any safety concerns? What do I need to know and do to be successful? Can I afford this treatment? What support is available to me?
As confusing and overwhelming as any medical diagnosis and treatment can be, insurance coverage and the cost of medication can be just as bad. In recent years, there’s even been research on “health insurance literacy” to develop a deeper understanding of how consumers understand and navigate health insurance, whether that’s Medicare, Medicaid, or commercial insurance. If we assume the intent of this law is to empower healthcare consumers, then it’s critical that marketers consider the conceptual model of health insurance literacy to ensure these communications take into account key knowledge needs, such as defining terms (i.e. covered eligibility, individual eligibility, deductible, commercial insurance, etc.) and anticipate and support consumers’ knowledge-seeking behaviors in print, online, and through telephonic assistance. It’s really critical that consumers are not left with more questions than answers that might ultimately hinder getting the best care to all.
How do you strategically incorporate the list price into your brand’s TV commercial without losing any creativity?
Blackwell: To me, the impact of complying with the law is less about losing creativity and more about losing valuable time, particularly when you’re dealing with something like a 30-second spot. Time is precious, and it’s likely that pricing will be treated like fair balance. This cuts into time, but it will be important to communicate clearly one way or another. That may include the use of supers or text.
Again, given the complexity and variability of costs, the PhRMA concept of directing people to a toll-free number or website does seem to make sense. Knowing we must find ways to convey pricing, the key is to do it directly and to ensure people can easily understand what we’re saying and the implications for them—with the ultimate goal being people get the best medicines and are clear on all the support that’s available to them, including financial support.