Most pharmaceutical companies have interdisciplinary committees with regular team meetings to discuss and review promotional
material. Promotional review committees (PRCs) provide this essential function for pharmaceutical companies. They review all
forms of advertising and promotion for medical accuracy, completeness, and realism, as well as for legal and regulatory compliance
with the FDA and other authorities. PRCs also ensure compliance with company policies, voluntary industry codes, and anything
that might create liability risk for the company, including patient privacy, and related content issues.
In addition to advertising and promotion, PRCs may also review unbranded, disease-state information and internal communications
that describe marketing strategies or provide direction to the sales force. PRCs touch many parts of the organization, not
only sales and marketing, but also R&D and health economics and outcomes research. Integrating data from clinical trials and
other sources into advertising and promotion is one of the primary functions of PRCs.
PRCs must perform flawlessly, otherwise companies run the risk of receiving an enforcement letter from the FDA's Office of
Prescription Drug Promotion. Enforcement actions undertaken by the FDA may spark investigations by the Department of Justice,
sometimes resulting in significant fines, reputational harm to pharmaceutical companies and the industry, and corporate integrity
agreements that impose additional processes and restrictions on companies.
I have served on many PRCs in different therapeutic areas across several companies. Here are some best practices issues critical
to achieving high-performing teams.
Find a common voice. Given the diverse training and background of individuals who typically comprise the PRC—doctors, pharmacists, lawyers, and
others—it is nearly impossible to obtain one writing voice among team members. Yet, word-smithing advertising copy or writing
copy during team meetings takes up valuable time. PRC meetings should be spent optimizing claims and the promotional value
of marketing material rather than wasting time on rewrites. PRCs should employ an editor to handle the "King's English," and
any changes in advertising copy should be made only when absolutely necessary, as opposed to discretionary. No two people
have the same writing style, so teams should not deliberate on minor differences in wording that say essentially the same
thing. Be brief, be brilliant, and be gone.
Respect everyone's opinion. Differences of opinion among members of the PRC are inevitable. Although it is necessary to discuss these differences in team
meetings, ultimately the PRC as a team is accountable for resolving any disagreements. Medical, legal, and regulatory team
members must learn to trust each other and rely on the expertise of the individual in whose discipline the controversy lies.
Occasionally, highly contentious or risk-management issues may be escalated to an "executive" PRC to overcome an impasse,
but no one should ever be insulted or attacked for his or her opinion. Collegiality must prevail in all instances.
Create dedicated roles. Team cohesiveness develops over time, especially when dedicated positions are created on PRCs for each team member. A rule
of thumb is that every hour spent in team meetings requires approximately two hours of individual review time before the team
meets. Thus, for a team that meets six hours per week, each team member should plan to devote 12 hours of review time outside
team meetings. This would be approximately the equivalent of a half-time position, assuming a 37.5 hour work week.
Maintain consistency. Continuity of team members from meeting to meeting is important. If there is a different representative from any discipline
on Tuesday versus Thursday, additional work and revisiting of position will occur. Product managers, who are vital to PRCs,
should be held accountable for carefully reviewing all material before it is submitted to the PRC to ensure consistency with
prior decisions. Rules that guide the decision-making process in PRCs should be applied consistently within and between teams.
Manage team turnover. PRCs should be aware that a change in team composition due to turnover may create friction or change the chemistry of the
team. PRCs should approach such a change with patience, helping to on-board new members while remaining receptive to their
suggestions. PRCs should refrain from responding negatively to new members. "That's not the way we do it"—and other dismissive
messages—are hurtful and unwelcoming. It is easier for teams to disregard feedback they don't agree with than hold themselves
accountable for change. By the same token, new team members should keep in mind that their entry may cause apprehension or
alarm in existing members. New team members should bring skills and experience from previous positions, but they should not
boast how a previous employer allegedly did things better.
Balance autonomy and teamwork. To be effective, PRCs must work diligently with a relatively high degree of autonomy. Otherwise, team meetings may become
suboptimal, bogged down by inefficient operations, potentially creating tension among team members and possibly compromising
the integrity of the promotional review process. PRCs walk a fine line, because the workload is divided among team members
from various disciplines who work independently, yet they must function as a unified team. A purely "divide and conquer" approach,
wherein individual team members work in a silo and seldom meet face-to-face, cannot be sustained.
Lead and influence. Even though PRC members are trained to be autonomous, promotional review is like a team sport, requiring the ability to be
both a team leader and a team player. Conflicts and "turf" battles often arise as to who has the final say in team meetings.
The truth is, although PRCs commonly fall under the leadership of regulatory affairs departments, a case can be made for medical
and legal departments to govern PRCs. Unless team members accept their roles as both a team captain and a team member, and
know when to exert their authority and when to acquiesce, dissention will ensue. Team members must also learn to appreciate
the differences between authority and leadership and how to influence others to change from the status quo. Leadership should
be viewed as a personal quality that enables an individual to influence others, independent of positional authority or the
ability to reward or punish others.
Adhere to timelines and deadlines. PRC meetings should start and end on time. The meeting agenda should estimate the time required for each job and avoid squeezing
too many jobs into the allotted meeting time. Jobs should be prioritized by a marketing operations committee well in advance
of team meetings. Generally, all material should be submitted a full week before it is expected to be discussed in a team
meeting. In this way, PRC members will have ample opportunity to review the material before the team meets. "Rush" jobs and
jobs that require expedited reviews are to be expected from time to time—for example, press releases and updates to the prescribing
information. Thus, the agenda should allow some flexibility, but it should not become a moving target in which jobs are constantly
rearranged or changed at the last minute.
Conduct all relevant business in team meetings. The goal of the PRC is to make clear and responsible decisions by having all the necessary medical, legal, and regulatory
personnel and resources in place during the team meeting. Working excessively offline, between team meetings and on weekends,
may signal a dysfunctional team. Responding to excessive e-mails and "copying all" can become fatiguing and disrupt the flow
of material into an otherwise healthy PRC. Team morale can become deflated by incessant job changes and requests for job approvals
outside team meetings.
Strive for economies of scale. In the traditional business model, PRCs are constituted around marketed products. In this model, the PRC reviews jobs that
are designed for both healthcare professionals and consumers, but there is usually only one dedicated team per product. An
alternative model is to segment PRCs into "healthcare professional" and "consumer" teams. In this model, each team is responsible
for reviewing two or more products, potentially achieving greater economies of scale (fewer overall PRCs). A third team—the
"disease state" team—could be tasked to review information promoted to increase awareness of diseases for which the company
has marketed products.