On Monday November 15 2010, I was delighted to receive another e-mail from MSWatch.ca, this time welcoming me to the new MSWatch Oasis:

Tell your friends:

There’s a place that we go to for comfort after a long day, where can help find some relieft and peace.  It could be your favorite part of the couch, the smell of fresh baked cookies or a phone call with a loved one.  Whenever you’re there, it’s as if you’re transported away. 

Today we’re exited to announce that there’s something new on MSWatch, a place where you can help build a world of understanding and support for the MS community. 

Keep track of your treatments and help manage your appointments in a fun and engaging way. 

Perch in the tree where you can find resources in the birdhouses and check in on fellow Oasis members. 

Chirp others in the tree and check in on your buddies. 

Earn badges just by keeping up with appointmens and therapy. 

Update your profile to connect with others in the MS community.  Add links to your Facebook, Twitter, blog and website. 

Join in to help manage your treatments, connect with other patients and caregivers, and access learning resources and helpful tools.  Help build a world of understand and support. 

So I decided to take a look at their new site.  I was able to sign in with my username and password from the original MSWatch.ca online forums.  After I logged on, I had the opportunity to let the community members know how I was feeling by selecting one of several pre-written statements.  This protects the pharma company from statements that could suggest an adverse event or one that could fall outside of Rx-DTC guidelines:

Then, I was prompted to update my personal profile.  As part of the profile, I could include my blog website, Twitter username, and FaceBook page.  This is a very interesting feature because it allows members of the community to meet each other on the MSWatch Oasis and then take their conversation onto their personal networks, where they are free to discuss all aspects of their disease and treatment.  Justin Seiler, Electronic Media (Marketing) Associate at Teva Canada Innovation, told me that MSWatch wanted to act as a ‘hub’ for their MS members.  That way, they are facilitating networking amongst the members, yet forcing them to go on third party sites.  As such, Teva Canada Innovation does not hold any responsibility of the discussions held off their site. 

Although direct communications between members do not occur onsite, you can see which community member is in the “Oasis”.  In fact, you can click on the person’s username to gain access to a limited portion of their personal information, including hyperlinks to their websites, Twitter and FaceBook profiles (assuming the member has updated their profile with this information):

Another very useful tool consists of the calendar which allows patients to input their treatment days as well as their appointments.  And as you can see in the pic below, community members can also ‘label’ themselves with a particular type of bird.  This is a great way to start a conversion with other community members (offsite, of course). 

Although I did not find this on the site itself, I did find it as part of the ‘tour’ of the website: badges.  It appears as though community members can earn different badges depending on what they actually do on the site.  Unfortunately, I was not able to see the range and meaning of the different badges. 

Going through the website, everything looks to be within Canadian pharmaceutical promotional guidelines, including Rx-DTC (where we are only allowed to mention product name, price and quantity).  Brands mentioned under treatment options include all of the players within this category, including a link to their individual support groups. 

Congratulations to Teva Canada Innovation for not giving up, and for finding a way to allow MS patients to continue to share with one another while staying within the Canadian Rx-DTC guidelines.  By maintaining the ability to help the MS patients network with one another, Teva Canada Innovation continues to achieve its strategic objective.  This is a valuable service for MS patients and I look forward to watching it grow quickly (as did the original MSWatch.ca online forums).  You have proven yourself to be a social media leader within the Canadian pharma industry! 

The agency that worked on the look and feel of the MSWatch Oasis is Twist Image.  This is the agency that was also involved in the redesign of MSWatch.ca that took place in 2009. 

Do you think the MSWatch Oasis is an effective social networking tools for MS patients?  Why or why not? 

Every once in a while, an organization stands out from the rest as a good corporate citizen.  For the past couple of years, I have been watching the good deeds by Telus which are positively influencing healthcare in Canada.  In fact, they are a sponsor of one of my favorite children non-profit organizations, Upopolis.  Here is a statement that is found on the Info tab of their FaceBook page:

We give where we live.  TELUS supports local communities and charities across the country. 

This week, I saw the following sponsored ad on my personal FaceBook profile:

When you click on the “Telus” link, you are brought to the “Like to give” tab on the Telus FaceBook page. 

Update November 26 2010: Pic with all 12 charities that were included in “Like to Give” Telus campaign

Telus allows comments to be added to their FaceBook posts, but they do not allow wall posts to be initiated by others.  I sent them a note on Twitter asking why this was the case, but 24+ hours later, I still had not heard anything from them.  My personal guess is that they do not allow others to initiate posts because they want to avoid negative dicussions being initiated by consumers on their page.  This seems to be an issue on the Telus YouTube channel.  Based on my research, Telus appears to get their fair share of negative comments on social networks by consumers, so if they want to avoid similar issues that Nestle had with their FaceBook page, they probably made the right choice by not allowing others to iniative wall posts.  Keep in mind though that the biggest issue with the Nestle case was the way that they handled the situation.  However, Telus is allowing consumers to have a voice as as those who ‘like’ the Telus FaceBook page can add comments to posts initiated by Telus themselves. 

Because of the high level of negative comments, I think it is wise that Telus’ Twitter strategy is to have a Twitter profile that is focused on marketing messages (@Telus) and one that focuses on providing consumers with support on Telus services (@TelusSupport).  This allows @Telus to remain focused on their positive marketing messages, whereas the @TelusSupport deals with all the questions and complaints.  However, I do find that the general @Telus account engages too little with the audience.  I did a quick monitoring check and noticed that several people have posted about Telus’ ‘Like to give’ campaign with a mention of @Telus.  This means that Telus does not even have to monitor to be aware of the mention – these public mentions can be found right there in their Twitter profile.  However, I have yet to see a ‘thanks’ sent out to any of those people, including myself.  This is not the end of the world, but it would be a courteous act which would humanize the organization in the eyes of consumers. 

I would like to wish Telus and their chosen non-profit organizations the best of luck in reaching their goals with the ‘Like to give’ campaign.  I am not a client of Telus, but their acts of generosity certainly catch my attention.  If ever I am in the market to switch, Telus will at least be top of mind as part of my research. 

What else would you like to see Telus do to promote their ‘Like to give’ campaign on social networks? 

Eye for Pharma organized the 1st eMarketing Canada conference, which was held in Toronto, on November 1-2 2010. 

Patrick Massad (Chief Review Officer at the PAAB, Pharmaceutical Advertising Advisory Board) presented an algorithm to facilitate the regulatory thought process when planning a social media promotional activity.  Here is the suggested algorithm:

1) Is this advertising? 

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2) Who is the intended audience? 

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3) What restrictions should I consider for this audience with respect to disease and product schedules? 

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4) What mechanism will I use to limit access to that audience? 

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5) What is the sponsor’s tolerance for uncertainty & risk? 

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6) How will I align the site with this tolerance level? 

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7) What are the regulatory consequences of adding and/or linking other tools/content to my site? 

Here are some highlights of Patrick’s presentation with regards to the very 1st step to detemine if tactic in mind is advertising or not:

Health Canada’s definition of advertising is as follows: “any representation by any means whatever for the purpose of promoting directly or indirectly the sale or disposal of any food, drug, cosmetic or device” (as per section 2 of Food Drugs Act). 

•What influence does the drug manufacturer have on the message content? 

•What is the content of the message? 

•With what frequency is the message delivered? 

By answering these questions, the intent of the promotion becomes clearer as to whether the tactic is advertising or informational. 

The intented audience and type of drug will determine which regulatory body needs to be consulted.  See this article here if you need assistance to determine which Canadian regulatory body to consult for your promotional campaign. 

On Friday October 15th, just a bit before lunchtime, I received an e-mail from an MSWatch.ca e-mail address with the title “The MSWatch Website is Changing“.  I was eager to read the e-mail because I assumed there would be some exciting features added to the site.  To the contrary, it was an announcement that the MS online community forum within the website would be removed effective October 15 2010. 

The e-mail read as follows.  Note that I took the liberty to bold portions of the statement that I felt were relevant to this post.  There were no bolded or highlighted statements in the original document:

We have, since 2002, grown and changed with the multiple sclerosis community, who learn, share and cheer each other on every day.  We’ve changed the look and feel of MSWatch.ca, we’ve added resources regularly and we’ve adapted when you reached out to tell us what you want from the website.  It’s been a delightful and inspiring journey, one that we hope to keep going for years to come. 

Part of that growth and change has included the MS Watch forum, where community members exchange ideas, information and personal messages.  It is with deep regret that we must announce that on October 15th 2010, the MS Watch forum will be closed.  This was an extremely difficult decision to make, with personal implications for everyone who has read or shared their thoughts and feelings in a forum post. 

Because the forum grew over time into a popular place to discuss Multiple Sclerosis, patients naturally gathered together to discuss their individual treatments which included both the good and bad that may have impacted themselves and their MS.  Unfortunately, for any pharmaceutical company sponsored website, the company is responsible to ensure that the content conforms to the requirements of the Food and Drugs Act and Regulations.  Teva Canada Innovation is responsible for all content that might be on the site regardless of whether it is mentioned in a community forum.  We believe that your discussion of your therapy is an integral part of your discussion of the issues you face with MS.  As a result, we felt that it would be inappropriate for us to monitor, edit and/or remove any posts that could be misleading or promotional about any individual therapy. 

This has left us with the difficult decision to close the forum element of the website as of October 15th.  This is not a decision that Teva Canada Innovation takes lightly.  We know how much the forum conversations mean to everyone in the MS Community – us included – and it is difficult for us to make this announcement.  When you come back on October 18th, you’ll still be able to log in as always and see all of the great content of the site, but the Community Forum will no longer be there. 

The connections all of you have made with each other and the support you consistently offer are truly inspiring.  We encourage you to take that spirit of camaraderie and extend it to other spaces for the MS community.  We are now and will remain available to community members by email at info@mswatch.ca or by phone to Shared Solutions at 1-800-283-0034. 

It is our privilege to play a role in this very special community.  Our sincerest thanks go to the members who were always posting, following up and keeping the conversation going.  It’s our hope that you’ll continue to consider MS Watch a valuable destination for MS information. 

So what was the issue with the site?  It was a regulatory issue.  Since the MSWatch.ca community was non-gated, anybody could become a member quite easily.  As a result Health Canada views the site as open to the public.  Forum postings by the members were not restricted to product name, quantity and price.  In Canada, direct-to-consumer (DTC) advertising of Schedule F prescription products is highly restricted in that only the name, price and quantity can be discussed. 

The content included in the site by Teva Canada Innovation themselves appeared to be within the regulatory guidelines.  The problem was that the members were discussing various MS treatments in the community forums beyond what is allowed by Health Canada (name, price, quantity).  According to the “Social Media Marketing in Pharma: What Works in Canada” conference, a pharmaceutical company is responsible for all content within their site, regardless of who posted it.  So when MS patients were sharing information with each other about their treatments on the MSWatch.ca forums, Teva Canada Innovation held full liability for this content. 

The following pics demonstrate how the online forums were promoted on the site, and what they looked like as well:

Here are some of the most notable changes within the website as of October 18th 2010:

Could the MSWatch.ca forums have been modified in order to comply with the Canadia regulatory guidelines (DTC)?  Teva Canada Innovation could have allowed members to continue to use the forum if the company would have taken the responsibility to edit or remove content that fell outside of the Canadian guidelines.  As MSWatch.ca is a very popular site (10,490 members as of October 15 2010), and the forums were very active, monitoring, editing and removing content would have resulted in a substantial effort o behalf of the company.  Moreover, it would have completely changed the context of some discussions, and some of the site members might have been upset about this. 

How does this compare with the American versio, MSWatch.com?  MSWatch.com, does not host an online community.  Rather, they link to the U.S. National Multiple Sclerosis Society’s online forums.  This gives them much greater flexibility. 

Does the Canadian MS Society hosts its own online communities?  Yes.  In fact, they host four separate online forums.  The first three are aimed at various members of the family: MSforKids.com, MSforTeens.com, and MSforParents.com .  All of these forums were launched in 2004.  In 2006, a fourth forum focused on general discussions was launched; MSDiscuss.com . 

Is there an opportunity for an organization like Teva Canada Innovation to sponsor the MS Society’s online forums?  Unfortunately not.  At the moment, the MS Society is not open to this type of partnership.  On October 19th, I spoke with Darrel Hominuk, Director of Client Services of the MS Society, and openly asked him if the MS Society would consider accepting an at-arm’s-length sponsorship of their online forums by a pharmaceutical company.  He mentioned that the society would like to maintain their independence at the moment. 

But at least this is an alternative option for MS patients and their families to participate online with a group of like-minded individuals all sharing experiences and concerns of living with MS. 

In conclusion, Teva Canada Innovation was a leader within the pharma industry by adopting social media principles and giving members free range to talk about anything that they wanted to talk about.  This is ideal and would be acceptable in many other industries, but unfortunately not in the Canadian pharmaceutical industry.  We have guidelines set by Health Canada that we need to abide to, whether we like these guidelines or not.  If following the guidelines means that your tactic no longer meets your strategic objective, then maybe it is best to put that tactic aside and try something different, something that does work within our guidelines.  I wish our DTC rules were much more relaxed, but at the moment, they are rigid.  Perhaps a debate to hold for a future post. 

Note that I am not an expert in Canadian regulatory issues.  I am merely providing my opinion based on the guidelines as I understand them. 

I hope this real Canadian healthcare social media case study is helpful.  Tell me what you think by leaving a comment.