December 2013

There are some interesting parallels in the FDA’s recent action telling the firm 23andMe to “cease & desist” all marketing of its personal genomics test with the recent news about Jeff Bezos and the Amazon “delivery drones”. Both are new technologies which will require regulatory understanding and adaptation.

However, by contrast, Amazon has floated (figuratively & maybe literally…) the drone idea, launching public discussion and regulatory contemplation. By contrast, 23andMe blazed ahead. Brave? Hubristic? Both?

The FDA’s approach is almost always to prioritize the prevention of harm. Is there potential harm (like unnecessary prophylactic organ removal) from misinterpretation? Probably. Can it be mitigated? Surely, but the FDA will want to be part of crafting the solution if it’s potentially accountable for the potential harm.

My experience running an orthopedic device firm taught me that firms consult with the FDA retroactively at their peril. Even now it is surprising how few medical & wellness firms have a regulatory control process in place for public-facing web content and mobile apps.

What are the practical lessons here?

Both are new technologies, which will require regulatory understanding and adaptation.
Both are best served by proactive vs. reactive regulatory engagement
Amazon has approached the regulatory environment more cleverly by “floating” its idea early.
It’s possible to re-engage after facing regulatory problems, but more difficult.
Inadequate or missing systems for regulatory content management is another area where many firms fail.

I hope 23andMe works things out with the FDA. It would have been far better to fully engage them earlier, but there is still hope.

Chris Messina

There are five valuable lessons from the phenomena-turned trend “Cyber Monday” for healthcare executives. First, Cyber Monday shows that anything can be marketed online, including healthcare. Second, demographics say that your audience will be online that day. Third, an effective web presence is critical in determining your success. There’s more; let’s get started with a story…

Like most, my e-mail box was flooded with “Cyber Monday” deals and offers. There were the usual “Get away to the Sunshine” travel and “Stock up NOW for Christmas” gift offers. However, more interestingly, strewn among the “Beethoven’s 7^th Symphony (42% off) and Leather Custom Photo Books (72% off) was a whole new class of sellers.

For the first time healthcare information and service offers were prominent. Harvard Medical School promoted its Health Reports at 20% off for the remaining 8 hours of Cyber Monday. There were local yoga, massage, and kick boxing class specials. More esoteric was the offer from Advamed, the trade association of large device manufacturers, offering a one-time Cyber Monday special of 20% off of courses ranging from “The PMA Process” to “Molecular Diagnostics and the Changing Landscape: Considerations and Implications”. In short, there were a lot of healthcare offers and they ranged widely.

Cyber Monday is the little brother to “Black Friday”, the deal-filled day after Thanksgiving. However as often happens with little brothers, it is on the way to dwarf its big sister. In-person live transactions are shrinking; the National Retail Federation (NRF) reported that Black Friday in-person retail shopping fell for the 1^st time ever in 2013- by 4.1%. By contrast, online transactions are growing. What are the big five “take home” lessons?

Lesson 1-Whether it is a good, a service, or information, Cyber Monday shows it can be sold online. Some of the fastest online sales growth rates are in service and information segments. That means that virtually anything can be promoted on Cyber Monday. However, chose your audience well. A deal on birth readiness classes in Seattle will not do well if promoted to seniors in Miami.

Lesson 2- Your specific audience, even if highly targeted or very local, is online on Cyber Monday. It’s not a fad anymore; 131 million Americans are estimated to go online shopping this Cyber Monday (52% of the US adult population), a 2% annual increase. Morever, they are projected to purchase 36% more goods, information and services this year than last Cyber Monday, according to analytics firm comScore.

Lesson 3- Beyond selling products and services, Cyber Monday can be leveraged to drive awareness for your mission. Even politicians have discovered this; this year the Republican National Committee (RNC) promoted Ronald Reagan lithographs at a Cyber Monday special 15% off, while a Democratic Campaign Committee touted a Cyber Monday promo of Elizabeth Warren wearables. In the healthcare world, promoting mission awareness is critical. For example, Advamed’s mission goes far beyond selling technical healthcare courses; they are promoting courses on Cyber Monday to raise the profile and impact of the medical device industry writ large.

Lesson 4- Your website needs to be prepared for Cyber Monday. A Healthcare.gov-type failure would not only hurt sales, it would impair credibility. Has your web presence been strategically planned, and is it regulatory-compliant? Demand to honest responses to the question, “Can our site(s) handle ten times its normal load?” Have your sites been “stress-tested across multiple platforms by a credible third party and have you seen the results? Is the user-experience friendly and consistent across varied browsers? Is there an accountable leader for each site?

Lesson 5- Your web presence must be mobile-friendly, on both Cyber Monday and beyond. Somewhere between 1 in 5 (comScore) and 1 in 3 (IBM) of all users will access sites this Cyber Monday from mobile platforms- smart phones & tablets. Deploying “responsive sites” or sites which auto-detect mobile access and reconfigure accordingly is critical. Body1 has a Mobilized™ web process that it uses to analyze and deploy health sites which anticipate, detect, and respond dynamically to mobile traffic. Some similar technical audit process should be required by every senior healthcare executive for all of their websites.

Savvy healthcare executives learn from multiple industries. Cyber Monday is a great lesson originating in retail proving that anything can be marketed online, including healthcare. The demographics show that most educated adults are online that day and many are prepared to act. However capturing those actions whether via a sale, a recommendation, or an introduction requires an effective, managed web presence.

“Cyber shopping” may not be for you. However, it is not a fad, it is a trend. As a result, “Cyber marketing” and “Cyber sales” should be top of mind for health and life science leaders—and not just on “Cyber Monday”.