Memorandum by Margot James (PI 110)
INDUSTRY
I am employed by Ogilvy & Mather (a subsidiary
of the WPP Group) as Regional President Europe of Ogilvy Healthworld
(OHW). OHW provides advertising, public relations and medical
education services to pharmaceutical and other companies in the
healthcare field. OHW employs approximately 200 people in the
provision of these services in the UK.
In 1986 I co-founded the largest specialist
healthcare public relations company in the UK that is now known
as The Shire Health Group (SH). I sold SH to WPP in 1999 and SH
is now part of OHW.
From 1998 to 2002 I was employed by Parkside
NHS Trust as a non-executive director. I was chairman of the Audit
Committee and the Clinical Governance Committee. I provided expert
advice on the rebranding and marketing of the Royal London Homeopathic
Hospital and the re-engineering of the wheelchair service for
West London.
From 1997 to 2002 I acted as a mental health
manager for St Charles Hospital which involved sitting on lay
panels hearing patient appeals against a section under the mental
health act.
From 1998 to 2003 I was a member of the "Informed
Patient Initiative" task force of the Association of the
British Pharmaceutical Industry (ABPI). I was involved in the
development of the MHRA Disease Awareness Guidelines issued in
2002.
SCOPE OF
WRITTEN EVIDENCE
My evidence relates to the impact of the industry
on the provision of drug information, promotion and the provision
of professional and patient education. In line with the Committees
terms of reference I have touched upon the influence of the industry
on health policies, professional bodies the media and the general
public.
1. Public Relations (PR) services are undertaken
by our firm on behalf of many leading pharmaceutical companies.
It is generally used to communicate news and feature material
designed to affect the market for our clients' products in an
appropriate and effective way. We measure success according to
the objectives of the campaign. Objectives can vary widely but
mostly it is about facilitating an environment that is favourable
to one or more of the following ends:
— Creating awareness and better informing
healthcare professionals and/or patients and/or members of the
public about a particular medicine and/or range of treatment options.
— Creating awareness and better informing
healthcare professionals and/or patients and/or members of the
public about a particular disease area.
— Improving the detection, diagnosis,
treatment and management of people with medical conditions and/or
people who are at risk of developing medical conditions the symptoms
of which may not yet be apparent or may be silent ie not expressing
themselves as feelings of unwellness.
— Generating a positive commercial
outcome for our clients.
We are expected to deliver against any objective
within the strict regulatory framework that governs the pharmaceutical
industry. (For more information see paragraphs 4 and 6 below).
2. Advertising and PR work in different
ways. Advertising works by crystallising the product's features
and benefits into a minimum number of key messages that, if well
executed, leave an impression on the mind of the target audience
that is favourable to the brand. The medium is usually "paid
for" space in magazines aimed at healthcare professionals.
Brochures are also developed for use by the sales force which
go into more detail about the product's features and benefits
than is possible in a one or two page advertisement. The difference
between advertising and PR is that advertising is paid for and
the content is controlled by the company paying for the advertisement
(within strict regulations see paragraph 4) and the media in which
it appears. PR on the other hand is not controlled by the company
and is not paid for (other than in fees to a PR firm or salaries
to PR professionals employed by the company). PR is reliant upon
the views of third parties such as patient organisations, professional
associations and journalists. PR is capable of delivering a more
complex set of messages about the product/disease area than advertising
and because of its dependence on third parties the outcome will
be more authoritative but precisely because of that dependence
on third parties the outcome will also be beyond the control of
the company.
3. In addition to advertising and public
relations OHW provides medical education (ME) services. This is
the practice of educating clinicians through meetings, articles
in journals, congresses, distance learning materials and the web.
Previous witnesses to the Health Select Committee have criticised
the practice known as "ghost writing". The rules we
follow to preserve the integrity of articles written by our editorial
staff on behalf of doctors are as follows: the doctor or researcher
discusses the content of the article with the writer and the writer
submits draft copy to the doctor for approval. The doctor puts
his or her name to the article once he or she is satisfied that
it is a fair reflection of the subject and their views. Some doctors
do not have the time or the writing skills necessary for publishing
their own work and value this service.
4. The communication between pharmaceutical
companies and healthcare professionals (whether direct or via
a consultancy) is regulated by: the Health and Medicines Act,
the EU directive on the advertising of medical products, the MHRA
guidelines and the ABPI code of practice. Staff working for OHW
(and all agencies to the best of my knowledge) are made aware
of the regulations. Training courses are held regularly to encourage
one hundred per cent compliance with regulations and the ABPI
code of practice.
5. The above mentioned regulations cover
promotion and education around particular medicines. Some PR activity
is aimed at patients and the public and is focussed on education
around a disease area rather than a specific product. OHW's work
in this area adheres to the MHRA Disease Awareness Guidelines
which requires that information communicated to the public be
accurate, up to date, substantiable, comprehensive, balanced and
accessible with the source identified clearly.
6. Communication with the lay press is governed
by Clause 20.2 of the ABPI code of practice and all PR staff understand
the importance of adhering to this part of the code in their dealings
with journalists. This section of the code reads as follows "This
clause allows for the provision of non-promotional information
about prescription medicines to the general public either in response
to a direct inquiry from an individual, including inquiries from
journalists, or by dissemination of such information via press
conferences, press announcements, television and radio reports,
public relations activities and the like. It also includes information
provided by means of posters distributed for display in surgery
waiting rooms etc. Any information so provided must observe the
principles set out in this clause, that is it should be factual,
balanced and must not be made for the purpose of encouraging members
of the public to ask their doctors to prescribe a specific medicine."
In general communication with lay journalists is confined to
disease awareness, the launch of a new product and the communication
of significant product news post-launch eg a major study that
has implications for clinical practice.
7. I have experienced the influence of the
industry in varying contexts. In general the British medical environment
is a conservative and sceptical one as measured by the uptake
of new medicines relative to other markets. The decision to prescribe
one product or another or no product at all is a complex one that
is influenced by many factors including the media (public and
professional), word of mouth among doctors and patients, prescribing
guidelines issued by hospitals or primary care trusts, the Department
of Health, patient groups, individual opinion leaders and the
pharmaceutical industry.
8. In my experience the dominant influence
over prescribing is Government through initiatives like the National
Service Frameworks and/or budgetary constraints. Whilst a mental
health manager at St Charles Hospital I observed that few patients
were on modern treatment for psychotic conditions. When I asked
why this was I was informed that budgetary constraints precluded
the wider use of atypical anti-psychotics despite their superior
side effect profile and the fact that non-compliance with older
therapies created a problem for the hospital, patients and the
wider community. There are numerous examples of Government/DOH
inspired resistance to newer treatments on grounds of cost which
has and still does prevent patient access to superior medicines.
9. During previous hearings members of the
Health Select Committee have heard witnesses claim that pharmaceutical
companies have too much power in the market place, spend too much
on promotion of medicines (such that non-medical interventions
are swamped out of the market place) and engage in practices that
"over medicalise" the problems of ordinary life. If
those allegations were true I believe that many patients who are
currently on old treatments which have been superceded by treatments
that have fewer side effects and/or are more effective (or are
on no treatment at all) would by now be on modern treatment. This
is particularly the case in the management of hypertension, schizophrenia
and oncology.
10. With regard to non-medical interventions
much of the work undertaken by OHW on behalf of clients emphasises
the non-medical interventions that can be effective in certain
conditions as part of the holistic approach to the disease in
question taken in our educational material. If the medicine concerned
is a statin then diet will be emphasised as first line therapy
in most cases, companies will work with dieticians to provide
high quality dietary advice although they have no financial incentive
to do so. If the medicine concerned is a treatment for asthma
then excersise, in particular swimming and tips on minimising
house dustmites will be emphasised. There are numerous other examples.
The reasons for the holistic approach are twofold, firstly out
of the client's sense of corporate social responsibility and second
because on the PR and educational side of the communication mix
companies are working, for the most part, with third party organisations
eg patient groups for whom a holistic approach mentioning all
treatment options, non medical and medical alike is a fundamental
requirement. Any company wishing to over promote its product at
the expense of fair balance and/or proven non-medical interventions
will not find a credible third party willing to work with them.
11. It is essential that a plurality of
sources of information continue for patients, professionals and
the public. Serious health inequalities persist for example:
between different postcodes, between younger people and the elderly,
between men and women, between the mentally ill and physically
ill, between different socio-economic groups, between those who
suffer from conditions where government targets abound and those
who suffer conditions where there is less scrutiny and publicity.
There are many groups committed to ending these inequalities but
it will take time. Pharmaceutical companies are more regulated
and restricted in what they can communicate than any other stakeholder.
It is right that they should be heavily regulated in what they
say about diseases and their own medicines but to restrict them
further would leave government as the majority voice in healthcare
with the under resourced voluntary sector trying against the odds
to make it's voice heard. We should embrace the fact that industry
has `an interest' in securing better knowledge about diseases
and improved access to treatment and leverage that interest in
the battle to overcome health inequalities.
Margot James
9 December 2004
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