Jennifer Carroll, Director of Communications at PAAB on the Past, Present and Future of PAAB.

[00:00:01] Welcome to the PharmaBrands Podcast. I'm your host, Neil Follett, and I'm happy that you're here. Speaking of happy, I'm also very happy to announce that this season of the PharmaBrands Podcast is brought to you in part by NFA Health. We really appreciate the support.

[00:00:16] Today, I'm chatting with Jennifer Carroll, Director of Communications at the Pharmaceutical Advertising Advisory Board. There isn't a conversation about pharma marketing that doesn't include some mention of PAAB, so it felt fitting to do a bit of a deep dive with Jen. Jen's been at PAAB through a lot of change, and in today's show, we cover a little past, a little bit of present, and a little bit of the future of PAAB. I hope you enjoy it.

[00:00:42] Thank you for joining us this morning, Jen.

[00:00:44] Thanks for having me.

[00:00:45] I'm going to ask a really big pressing question right off the top of the conversation here. Probably the thing that everybody has tuned in to find the answer to. Is it PAAB or is it the PAAB?

[00:00:58] You know, that's a funny question that people always ask. I use them interchangeably. You can say the PAAB or PAAB. I guess, contextually driven, I have no preference.

[00:01:10] Okay, good. So I can call it PAAB and then not look like a fool for the rest of the conversation.

[00:01:14] Absolutely.

[00:01:16] Your LinkedIn profile says that you've been at PAAB for 15 years and 11 months. Are we like just about to hit your 16th year work anniversary?

[00:01:27] Yeah, we are. January 6th is actually when I started.

[00:01:32] Amazing. 16 years is quite a run at one place. I have to imagine you've seen quite a transformative shift in PAAB over those 16 years.

[00:01:47] I know there was a very meaningful change in leadership over to Patrick a number of years ago. Volume levels are quite extraordinarily different. We can talk about that in a few minutes, but volume levels are different.

[00:01:57] The size of the organization is different. Maybe just give listeners kind of a bit of a 16 years in a few minutes. Like what has 16 years at PAAB been like?

[00:02:07] Yeah. I mean, I personally think it's been really phenomenal. Definitely when I started at PAAB, I didn't think I was going to be staying there for 16 years.

[00:02:17] No one does. No one does often.

[00:02:18] So I had done my co-op placements in Pharma and I absolutely loved it. And so my goal was to end up in Pharma. But the longer I was at PAAB, just the more I believed in the mission and the values and the vision of it.

[00:02:33] And to your point too, we've had some leadership change and the new leadership is definitely driving PAAB in a direction of growth and collaboration and opportunities to really have a wider and greater impact on healthcare and healthcare advertising and marketing, which I particularly love.

[00:02:54] I feel passionately about it. And so it's made it easy to kind of stick around for 16 years and still feel like there's more change to come and more growth opportunities.

[00:03:06] Definitely seeing the team grow almost double during the pandemic was a huge testament to the willpower of the staff who had to absorb that kind of extra training burden during the time.

[00:03:21] But now I think we're sitting in just a really strong position of well-trained staff who are also aligned with the vision and who believe in healthcare and the value that, you know, drug advertising can bring to healthcare, which is, it's a great place to be in an organization.

[00:03:38] You're now the director of communications. Are you also doing reviews and doing director of communications or is it just focused on the comms part?

[00:03:45] No, absolutely. Still doing reviews. I think that in order to know what the industry needs to know about and how to communicate with them and what the trends are, you kind of, it's hard to step away from reviews completely.

[00:03:58] You have to kind of keep your finger on the pulse of those things in order to know what's next or where additional training is needed and things like that.

[00:04:11] So, yeah, I still participate in reviews. I'd say about 25% of my workload ebbing and flowing, sometimes up to 50.

[00:04:19] But, yeah, still actively participating in reviews.

[00:04:23] I am, admittedly, I have not memorized these numbers. I'm actually looking at the PAB website, looking at numbers of submissions.

[00:04:31] Submissions really quite materially blew up between 2019 and 2020, and then again, 2020 to 21, and even growth from 21 to 22.

[00:04:40] How many people are at PAB now? Like, what's the size of that team?

[00:04:45] Forgive me for not having these numbers memorized, but I think we're still at 31 staff right now.

[00:04:53] And that's distributed over administrative staff and then directors.

[00:04:58] There's four directors, a number of senior reviewers, and then reviewers.

[00:05:04] Okay.

[00:05:05] So, they're sitting at a pretty good number right now.

[00:05:08] Yep.

[00:05:09] I feel like, you know, leading up to the pandemic, people were just working at like 120% all the time.

[00:05:15] And growing that staff has really allowed us to kind of drill that number back a little bit so that we're not burning out people.

[00:05:25] Yeah.

[00:05:25] Because it is a mentally taxing position.

[00:05:30] And so, let's talk like reviewers for a sec.

[00:05:34] And I'm going to, so just so you can situate yourself into where my brain is at, I'm going to ask you about reviewers.

[00:05:39] And then I actually want to just sort of pause for a second and go back to kind of when did PAB start and what was the original mandate and has that changed and all that kind of stuff.

[00:05:49] But let's just talk about reviewers for a sec.

[00:05:51] And I don't know if people know, but what does it take to become a reviewer?

[00:05:57] Is there a typical profile of someone who's a reviewer?

[00:06:02] Do you sort of look at a resume and go, oh, that's the ideal profile of a reviewer?

[00:06:07] Give me a bit of a sense of the folks.

[00:06:09] But what does it take to become a reviewer?

[00:06:11] And what do their backgrounds typically look like?

[00:06:14] Yeah, it's a really good question.

[00:06:16] And it's so interesting.

[00:06:17] I think if you had asked me that question 10 years ago, I'd probably have a different answer in that I'd say I was like an anomaly.

[00:06:24] And that, you know, a lot of people who were reviewers are very analytical, A-type.

[00:06:32] They wanted to know, you know, just review the data, make comments, and move on to the next one.

[00:06:40] Exactly.

[00:06:40] And for a good way to put it, it was like just very, I want to do my job and be excellent at it.

[00:06:50] But maybe if you were to ask them to go out and do a presentation, they'd be like, ah!

[00:06:55] Yeah.

[00:06:56] That terrifies me.

[00:06:57] Yep.

[00:06:58] And so over, you know, while we were expanding the team, there was real thought put into, you know, making sure that we had diversity across the team from just personality types.

[00:07:10] I'm sure you guys have all done like the Myers-Briggs and those types of like, are you red, green, yellow, blue?

[00:07:15] Yeah, I was going to say, even if you're asking that, I'm like, I know I'm a color.

[00:07:19] I just can't remember what color I am.

[00:07:20] Yeah.

[00:07:21] And it depends what one you did because I find like in some yellow means something and in another yellow means something completely different.

[00:07:27] Yeah.

[00:07:27] But the idea that when we did it, the entire team sat in one block and then, you know, I was sitting over here in this block all by myself.

[00:07:35] But now we really have distribution across those colors.

[00:07:38] You know, I think that you still require that analytical brain, that attention to detail, ability to critically appraise trials and data and claims.

[00:07:51] But we also look to add people in who have a little bit more of that social outgoing personality, making sure that, you know, the team as a whole is really comprehensive of different personality types because everyone brings something different to a review.

[00:08:09] And then the way we try to create consistency across that is by having weekly meetings and talking things out and hearing other viewpoints so that, you know, when you have, hey, I'm going to question this.

[00:08:21] I'm not going to go find someone who thinks the exact same as me.

[00:08:23] I'm going to go find someone who thinks differently than me and see, do they have the same opinion?

[00:08:28] And I think that that creates a more holistic approach to the reviews.

[00:08:33] And hopefully people over time, over the last, you know, 10 years, if they reflect back to what they would have got 10 years ago versus what they're getting now, hopefully they start to see and feel that change.

[00:08:44] And so what does it take to become a reviewer?

[00:08:47] I mean, I think anybody who's taken a quick look at the PAB code knows that it's not an easy read.

[00:08:53] There's lots in there.

[00:08:54] And PAB reviews are an absolutely critical part of getting a piece of work through to market.

[00:09:01] So obviously there's got to be, you know, a lot of training and a lot of familiarity.

[00:09:04] What's the sort of process?

[00:09:06] Like somebody starts, there's obviously some training.

[00:09:08] And then, you know, are they a junior reviewer under a supervisor?

[00:09:11] Like how does that progression work as a reviewer comes in?

[00:09:15] It's very structured in a sense.

[00:09:17] So right out the gate, we're always looking for people who have like a science background.

[00:09:21] It would be very hard to do reviews if you didn't have some sort of science background or training.

[00:09:28] And then once they start, training is about eight months.

[00:09:33] And during that time, they go over past case examples, iterations of the code.

[00:09:39] We look at guidance documents, internal kind of key review rulings.

[00:09:44] And then they'll start to get little test examples where they'll put what they've learned to the test.

[00:09:50] Kind of similar to how our past training, live training sessions went.

[00:09:55] Like here's an ad, write a letter for it.

[00:09:57] Okay, now you're going to sit with a reviewer and they're going to help you improve on what might have been missed or the way in which you worded your responses.

[00:10:06] And that goes on for a while.

[00:10:08] And then they'll start to do, once they reach kind of an acceptable level of knowledge retained, they'll start to get live files that are concurrent with a full reviewer who's doing the files.

[00:10:22] So their letter still won't be sent out to clients, but then they'll be able to compare their letter to the reviewer's letter that went out to clients.

[00:10:28] They'll learn through that.

[00:10:29] Then eventually they'll start to write their own letters, but a reviewer, usually a senior reviewer or a director will look over all their letters, you know, discuss any points and stuff before their letter goes out.

[00:10:43] And then we try, once that they're at a level where, you know, there's very little comments being made in addition, so they're not missing much.

[00:10:51] Then they'll break out on their own, but they'll be paired with whoever is either second on that brand or who's leaving that brand.

[00:10:59] Like if they're going to be taking over as primary reviewer on that brand, the former primary reviewer will be still, they'll still kind of be checking all of them before they go out.

[00:11:10] And then they'll move to a position where they just get checks when they aren't sure.

[00:11:16] And that's when they would be deemed a full reviewer.

[00:11:19] And it's kind of becomes at their discretion to reach out to other reviewers if they have questions.

[00:11:27] And definitely at the beginning, there's lots of questions and they're not shy.

[00:11:31] They're definitely encouraged to reach out a ton and they'll do that.

[00:11:37] And the rest of the team supports them.

[00:11:39] And over time, it just becomes less and less questions as they get more examples and more experience to go off of.

[00:11:46] But it sounds like a lot of effort and discipline is put in on your side to ensure that when a letter hits sort of somebody's inbox or hits their desk, it is coming from as deep a place of knowledge as possible.

[00:12:01] Absolutely.

[00:12:02] And that's why the training process takes so long.

[00:12:05] And we don't have like, okay, you hit eight months, you're free.

[00:12:08] It's like we really go with, you know, how are they progressing along that training?

[00:12:13] What is their comfort level with doing reviews?

[00:12:15] What is our comfort level?

[00:12:17] Like we don't want to be in a position where we're just being like, have fun and whatever happens, happens.

[00:12:23] No.

[00:12:23] Yeah.

[00:12:25] Agencies and clients, they rely on us to be giving them a solid review right from the beginning.

[00:12:31] That's part of our KPIs and our mission and our mandate is to just make sure that we're providing the highest quality service that we can.

[00:12:39] And that means, you know, intensive training.

[00:12:42] And it's funny because we always say like, you know, we offer lots of training and people are like, I did training five years ago.

[00:12:49] Like I know PAB.

[00:12:50] And it's like a one day training doesn't mean you know PAB.

[00:12:53] Like reviewers take months and months of day in and day out looking at examples across all agencies, all brands, all therapeutic areas to become experts in the code.

[00:13:05] And what training the, you know, agency and industry training offers is just familiarity.

[00:13:11] So that when you see a comment, you can kind of be like, oh, I remember they did say something about that.

[00:13:17] Yeah.

[00:13:18] I recognize some of these words.

[00:13:20] Yeah.

[00:13:20] In my time in the industry, I've probably taken the PAB training a number of times.

[00:13:26] And I think it's fair to say I didn't come out of any of those as much of an expert and relied very heavily, both on PAB, but also people within my organization or my past organization to say, no, Neil, you can't, you can't do that.

[00:13:40] So let's go back to when was PAB founded?

[00:13:43] Kind of what was the original mandate?

[00:13:45] And yeah, get it like, take us, take us back to where it started.

[00:13:47] Yeah, I guess I'll be very roughly speaking in that like.

[00:13:52] Yeah.

[00:13:52] Appreciating that you haven't sort of memorized the history.

[00:13:54] Yeah.

[00:13:55] And I wasn't even alive.

[00:13:57] So yeah, but PAB was started back in 1976 and it was a response to kind of concerns around accuracy and ethical standards within pharmaceutical advertising that was directed at healthcare professionals.

[00:14:14] At the time, there was kind of this risk that Health Canada was going to step in and review all material or even potentially say no more advertising at all.

[00:14:23] Yeah.

[00:14:24] So no information to patients, no information to healthcare professionals.

[00:14:28] You shouldn't be advertising.

[00:14:29] And a group of people kind of were like, no, advertising has value.

[00:14:34] And there was this understanding that it could provide a lot of value to both healthcare professionals and patients.

[00:14:41] And so the group kind of said, hey, you know, let's look at how we can still make this happen.

[00:14:49] But maybe there needs to be an independent body that's monitoring the promotional material and ensuring that it's, you know, scientifically accurate, balanced and compliant with the regulations.

[00:15:00] And so that was the creation of the PAB code.

[00:15:04] And the idea, which I think still holds true today, is that as an independent body, PAB could help safeguard healthcare professionals and patients from misleading or exaggerated claims, which could negatively impact patient safety, which is what we're all here to ensure at the end of the day.

[00:15:20] And so the code sought to ensure that there were ethical standards that were consistently applied across the industry.

[00:15:27] But also it was a way to bridge this gap between Health Canada's regulatory framework and its practical application in advertising and advertising specifically in the healthcare landscape, where things are just a little bit more complicated than if you're trying to advertise cookies.

[00:15:45] And so one of the biggest selling features of why, you know, preclearance and self-regulation can persist in Canada and why PAB provides value is that independent review can be objective.

[00:16:01] And it ensures that pharmaceutical companies are held to, that they're accountable to producing high quality, balanced and complete advertising.

[00:16:10] Where do you feel that industry is now in terms of that tension between kind of self-regulation or how do we regulate or should it be regulated in the same way?

[00:16:21] It sort of feels like that conversation kind of bubbles up every, you know, every few years.

[00:16:27] Yeah, I think, you know, it's so tricky and obviously I'm biased.

[00:16:31] Like I'm biased not only because of where I work, but because I've always had that kind of feeling of what is a mechanism or a layer that can add a level of trust to an industry where one bad actor can really destroy trust for the entire industry.

[00:16:53] And then I think of this argument of, well, we're going to pick and choose what we submit to PAB.

[00:16:58] But the idea is like, then you're kind of eliminating the whole value of preclearance.

[00:17:03] You're saying, oh, well, you know, if we think this needs to go, we'll submit it.

[00:17:09] But then that encourages people to start to move towards that.

[00:17:15] I don't think this is going to get through.

[00:17:16] So I'll just say it doesn't need to go through PAB.

[00:17:19] And then you start to, you know, I think of it like a line.

[00:17:24] It's very easy to see the line when you're far away and be like, oh, I know I'm so far from that line.

[00:17:28] It's OK.

[00:17:28] But as you get closer to that line, it becomes a little bit harder to know, like, am I too close?

[00:17:34] You know, maybe it's a fat line and I'm like standing on it and that's fine.

[00:17:38] OK, I only have one toe over the line.

[00:17:40] Like I'm still mostly on this side.

[00:17:42] Like, well, maybe I'll just bow the line out a little bit.

[00:17:45] You know, it's a little bubble around myself.

[00:17:47] But that has a way of escalating over time to where you get to a point where, you know, maybe the government is going to step in and say, no, fine, we're going to regulate you.

[00:17:57] And that's going to mean you can't do anything like you are restricted to word for word what's in your product monograph.

[00:18:03] You want to add a couple like logos and some colors go nuts.

[00:18:07] But that's all you can do.

[00:18:08] And I don't think that that's really what's going to provide value to health care professionals or to patients at the end of the day.

[00:18:15] So I think just understanding that there's always a push and pull and that regulations are are often uncomfortable, but they have a purpose.

[00:18:25] And keeping that kind of line across the industry says, hey, we're committed to ensuring that our own performance metrics and incentive structures don't put people in a position where they might cross the line unintentionally.

[00:18:43] Yeah.

[00:18:44] If that kind of makes sense.

[00:18:45] There is a value, I think, in having consistency that everybody's playing by the same rules and not have to be adjudicating some of those conversations internally.

[00:18:58] Like there is a there's an imbalance sometimes between an agency and a client and both ways.

[00:19:03] Right.

[00:19:03] Sometimes the agency saying, let's do this.

[00:19:05] And the client saying, I really don't think that's compliant.

[00:19:07] And sometimes it's the opposite.

[00:19:08] But trying to adjudicate that between a client and an agency is quite challenging sometimes.

[00:19:13] And so I think there's value in going to the third party and saying, OK, sort of you guys decide.

[00:19:20] You know, absolutely.

[00:19:21] And I love that that's what you say.

[00:19:23] And it makes me think of this example once that was like or I don't know if you've ever played sports.

[00:19:29] But like for myself, when I play sports that are, you know, self-officiated versus when there's an official, like the sport just goes down.

[00:19:38] Like how many times have you argued during ultimate?

[00:19:40] Exactly.

[00:19:40] Exactly.

[00:19:41] So like they just go down a different way.

[00:19:44] And that's not because one team is like a dishonest team.

[00:19:48] It's that when you have a vested interest, you can't be objective.

[00:19:52] And that's not to say you're a bad person or that you have, you know, bad morals or you're a bad actor.

[00:19:59] It's just that in the heat of the moment when you have a goal, it can be easy to be focused only on that goal and miss some other things.

[00:20:10] And so, you know, it's the exact same.

[00:20:13] Like every pharma company is basically an athlete on the field playing for their own team.

[00:20:19] And it's just easier when there's an independent ref who can say, hey, everyone's got to follow the same rules.

[00:20:27] You know, no slashing, no like kicking people from behind, no pushing.

[00:20:33] Like just do it right.

[00:20:35] Well, and the stakes like this, the stakes are really high when you think about it.

[00:20:41] Right.

[00:20:41] So first of all, you know, there is inherent ambiguity in creative work.

[00:20:46] Creative work is not sort of empirically creative.

[00:20:50] It is it's by its nature a bit amorphous.

[00:20:54] Right.

[00:20:54] And so you've got this work product that you guys are reviewing.

[00:20:57] You're reviewing it against like a very there's a scientific component to it.

[00:21:01] There's a regulatory component to it, you know, but there's also this kind of creative component to it of interpretations.

[00:21:05] And that's complicated.

[00:21:07] And it is the agency's business to do good work.

[00:21:13] And sometimes the definition of good work is work that kind of bumps up as close as possible against those rules of the game.

[00:21:21] It's in the client's vested interest to try to do work that is differentiated and breaks through.

[00:21:28] And so there's a natural tension in all of this where you're reviewing creative, which by its nature is open to interpretation from agencies for whom this is their, you know, their lifeblood for clients for whom this is going to go out in market is going to impact their brand and their job.

[00:21:47] And it is it's by its very nature, a particularly charged part of the industry that you guys are looking to regulate.

[00:21:56] It's a complicated thing, right?

[00:21:58] Yeah.

[00:21:59] And it's it's tough because we, you know, we share a border with a much less regulated country.

[00:22:06] When it comes to advertising.

[00:22:06] But the way I look at it is, you know, if it was easy, everyone would be doing it.

[00:22:13] And so there's a reason not every person who went through marketing and who is creative is working in health care.

[00:22:20] It's it's a tough space to be in.

[00:22:22] But what it does is it really challenges you to be the most creative version of yourself.

[00:22:27] And like that you can go and be like, I'm not just a marketer.

[00:22:31] I am a marketer in health care where I have impact and I have sway and that I'm going to improve the environment.

[00:22:41] I'm going to improve lives of Canadians.

[00:22:44] And I have to do that in a very highly regulated space.

[00:22:47] And then on a separate note from that, you know, at PAB, we've really been trying to make this movement towards how can we help you get to those creative gains?

[00:22:58] So if we can understand what the creative goal is, then we can try and work to help you be like, are there is there copy that could limit this creative?

[00:23:07] Or is there a small tweak to the creative that could still get the message across that you want?

[00:23:12] Well, being engaging, well, being captivating.

[00:23:15] Um, so really trying to move the perception of the organization away from a no, a no stamp to a like, here's how it can be a yes.

[00:23:28] We'll be right back.

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[00:24:17] You and I have known each other for a long time, and you and I have had this conversation for the, for the, you know, really for the most part, teams or my former team's experience with PAB was quite collaborative, right?

[00:24:29] Like a, a bit of a, you know, maybe not this explicit, but a bit of a, I know where you're trying to go, and you can't get all the way there, but, but sort of what about, right?

[00:24:42] And not a co-creation of the work in any way, but definitely not, not a no stamp.

[00:24:47] Yeah.

[00:24:48] And I think like, I love that you call that out because I think that where we have our best interactions are where people are just so transparent and honest with us up front.

[00:24:59] Like this is what matters to the clients.

[00:25:01] This aspect of the visual, or this is the message you're trying to get across.

[00:25:06] Sometimes that's going to be like, no, you can't do that because you don't have data for it.

[00:25:10] But other times it's going to be like, okay, well, these other messages exist.

[00:25:14] How can we limit those other messages so that they no longer exist so that the key message you want is actually coming across?

[00:25:21] And that's when we can really collaborate to helping you get to a state where it still meets the regulations, but the client perceives it to have value.

[00:25:31] So then building on that, and this is maybe a tough question to answer, but for all the agencies that are listening, what do you wish from agencies?

[00:25:42] I'm sure there are scenarios where a submission comes in or there's an interaction where it's just like, oh, that's, that's, that's not how we want this to go.

[00:25:49] And then there's others, just guessing.

[00:25:52] And then there's, there's, yeah, exactly.

[00:25:54] And there's other scenarios where you're like, oh, yeah, like this, this really feels like the way it should work.

[00:26:00] Can you maybe describe sort of maybe give an example of like, I would like to see less of this type of, you know, submission or interaction.

[00:26:09] And I would love to see more of this type, like give, give, give me a sense of that.

[00:26:13] Yeah.

[00:26:13] I think that goes back to exactly what I was saying about like just full transparency.

[00:26:19] Yeah.

[00:26:19] I've heard people say to me, you know, well, we're worried that if we tell Pab like what our goal is, then they'll never unsee that and they'll say no.

[00:26:29] And my thought to that is then you probably already know it's a no.

[00:26:32] Yeah.

[00:26:32] Yeah.

[00:26:34] So like that should be a moment of reflection of like, well, if it's a no, should I really be doing it?

[00:26:40] But if it's like, no, I think that this is a valid, like, you know, let's speak to creative.

[00:26:46] I think this is a valid creative and I want it to mean this.

[00:26:49] And we have the data for that.

[00:26:51] Then just tell us that.

[00:26:52] And we can then be like, okay, these are the other things we're seeing.

[00:26:56] And here are ways that you can limit it to the actual message that you want to convey.

[00:27:01] So almost using us as like to our namesake as advisors, like tell us your goal with the creative, tell us your goal with the copy and the message and allow us to sit there and say, okay, here are ways it can be done within the regulations.

[00:27:18] And then at that point, you know, a business decision has to be made by clients, but it can at least be informed in a manner that's like hopefully feels more collaborative and less like adversarial.

[00:27:36] Like I feel like when people respond to me in a very adversarial manner that sometimes I'm, I, I feel less inspired to be creative versus when people are like, just lay it on the table.

[00:27:52] Like, oh, help me out.

[00:27:53] This is like what I, I'm like, okay, okay.

[00:27:55] I want, I do want to help everyone out.

[00:27:58] I do.

[00:27:58] But the mindset you're in is more creative when you're like, okay, okay.

[00:28:03] I understand what they're getting at.

[00:28:04] What can I do to help you?

[00:28:06] Sometimes it's going to be like, there's nothing I can do to help you.

[00:28:09] And like, at the end of the day, we're not creative people that like our job is not to be creative, but that doesn't mean that we don't have ideas and thoughts that we can at least give you to then let your creative team run wild with within, you know, a focused direction.

[00:28:25] And I think that's, I think that's helpful, right?

[00:28:29] I think that likely there are organizations or individuals or, you know, whatever out, out there who see the PAB reviewer and the PAB mechanism as part, like an integral part of the process.

[00:28:43] And there are others that might see PAB as a portal through which you submit things and don't necessarily consider that there's kind of, you know, humans on the other side of it and aren't maybe applying the, you catch more bees with honey than you do vinegar approach.

[00:28:59] Right. So, yeah, I think that's important.

[00:29:02] And again, I'm a warm host for this conversation because I've typically through my past have, you know, the team has had, has tried to take that let's be collaborative and curious approach.

[00:29:15] And it's, and it's really quite borne out, you know, well.

[00:29:18] So, so speaking of submissions, I want to, I want to jump back to something earlier that we talked about, which is just volume levels.

[00:29:26] So again, full disclosure, not memorized.

[00:29:28] I'm looking at the website right now and, and basically like 20, I mean, honestly, 2012 to 2019.

[00:29:37] Look, I'm not gonna say it's flat.

[00:29:39] Some years are up maybe 10% and then down a couple of percent and, but it's, you're in and around the 70, you know, 7,000, 7,500 sort of submissions with, with a couple of outliers.

[00:29:49] And then 2020, it jumps to, to 9,000.

[00:29:53] 2021, it jumps to 10 and a half thousand.

[00:29:55] 2022, it jumps to almost 11,000.

[00:29:59] I think more recent numbers like 11,000 for, for, for 2023.

[00:30:02] So we may be, it may be leveling off and there may be another few years of your bouncing in and around that 11,000 number, but seven to 11 is a big jump.

[00:30:13] Can you talk about why do you think that is?

[00:30:15] And what are you seeing?

[00:30:17] Is, is there some category of work that has made up that bulk?

[00:30:24] Is that, that is 2020 sort of when all of a sudden like rep driven emails and, and omni channel really got fired up and no.

[00:30:32] So now there's just a million of those.

[00:30:34] Like, help me understand what that kind of curb is, is all about.

[00:30:37] I think there are a number of things that impact it.

[00:30:40] I mean, obviously the pandemic resulted in a lot of companies being like, shoot, we hadn't really thought about how we were going to get paper pieces into the hands of doctors.

[00:30:51] If we couldn't actually be in the doctor's office.

[00:30:54] So there was a bit of a spike and just that, that rush to get things digitized and get emails out.

[00:31:01] But then I think this realization that we're probably not going back to the pre pandemic world and that it was already hard to get time with a doctor, but now live time with a doctor is even harder to get, or at least that's what we've been hearing from the, from the industry.

[00:31:17] And so really making sure that when they're producing emails, that they're, they're targeted to a specific topic or a specific interest.

[00:31:26] And, uh, I would say even in, you know, 2016 through 2018, we would get emails that, you know, the copy deck would be like 20 pages long.

[00:31:37] And all I could think is what doctor is reading this email from start to finish.

[00:31:43] Like it's just not happening.

[00:31:46] Um, but now we start to see emails that are very topic driven.

[00:31:50] They'll have links out to the full website, but that, that idea of, you know, individual topics, bite size, uh, information.

[00:31:57] And I think that's very reflective of just, you know, the way learning is going across the world.

[00:32:03] This idea of like the tick tock generations coming through and their attention span is, you know, six seconds at best.

[00:32:09] So if you can't catch them, then like putting every one of your marketing messages in a single email is likely not going to be, is not going to resonate.

[00:32:18] It's not going to get the message across.

[00:32:19] And that's only just from like my personal, what I've heard out when we've, you know, we go to conferences and we hear feedback from marketers and that's, that seems to be the message.

[00:32:30] So I wouldn't say that's my message.

[00:32:32] I just, that's kind of.

[00:32:34] That's a personal message, not a Pabendors message is what you're saying.

[00:32:38] Yeah.

[00:32:38] Like we haven't run any numbers on like the length of content or length of pieces in particular.

[00:32:44] So I couldn't, I couldn't speak to that.

[00:32:46] But most like, obviously there has been an increase in digital tools and submission.

[00:32:52] I mean, all submissions come in digitally, but more submissions on the like websites and emails and apps, even increase in social platforms.

[00:33:04] So those types of things seem to be, and then it seems like marketing cycle.

[00:33:10] And this is more a reflection from when I started in like, oh God, like in 2009 of like marketing cycles seem to be like once a year, maybe you'd refresh it like halfway through the year.

[00:33:21] But now it seems like they're rolling on a much quicker basis.

[00:33:26] When I started, it was, it was a long time ago as well.

[00:33:30] And yeah, there was sort of a, we're going to update our paper detail aid, you know, twice a year would have been quite radical, frankly.

[00:33:40] And then we're going to sort of make sure the new messaging gets into our assets and, which is not necessarily consistent with what contemporary marketing looks like outside of healthcare.

[00:33:51] And I think that healthcare is likely, and has, I've seen it, you know, move more into channels where the, you know, the comms are more nuanced, nuanced, they're a bit more consistent.

[00:34:02] You know, in some cases, probably too, too consistent.

[00:34:05] There might be too much going on.

[00:34:07] But I think that that's a reflection likely of the marketing environment has changed pretty significantly.

[00:34:12] And I think the marketing maturity and channel adoption in healthcare has also changed pretty significantly.

[00:34:20] And to your point, accelerated by the pandemic, where I think that some of those channels, you know, digital, social, email, all that kind of stuff was, you know, we're active, but a bit more side of the desk.

[00:34:31] And then all of a sudden, your sales force gets, you know, grounded and those things go, you know, right to the top of the list.

[00:34:38] And to that point, we see even like, we envision that in the future, it's going to be even more in the sense of messages, not only will be targeted to, you know, an individual message, but also targeted to the user.

[00:34:54] You know, am I talking to a pharmacist the same way I'm talking to a specialist?

[00:34:57] Am I talking to a nurse practitioner?

[00:34:59] And so we're starting to see, and again, like I was at a conference last week, and they spoke to really tailoring your message for the type of prescriber that you're talking to, so that it has more impact.

[00:35:12] And so we anticipate that that's also going to affect volume over the coming years.

[00:35:19] Well, that's an amazing segue, John, because I was just about to turn the conversation towards the future.

[00:35:27] So I appreciate the help.

[00:35:30] You guys have an AI industry working group.

[00:35:33] There's a bunch of effort that I think is happening, because I've heard about it.

[00:35:40] You talked about it at our AI conference, and I know you're out chatting about it in general.

[00:35:45] It feels like there's a bunch of work happening right now in PAB that is anticipatory, like you're sort of looking to kind of future ready the organization for what is about to come.

[00:36:00] Give me a sense of what you guys are up to and maybe where you think things are going a bit.

[00:36:04] Yeah, so from a PAB perspective, things that we're trying to prepare for is this fear across the industry of we're going to produce a ton of content and we won't be able to get it through PAB because they don't have capacity.

[00:36:19] So we've looked for ways to streamline reviews and the submission process and what those things could look like so that if there is an increased volume of, let's say, I have an ad for my primary efficacy endpoint and I want to have six different versions of it, one for pharmacists, one for doctors, one for nurse practitioners, so on and so forth.

[00:36:44] I can submit all six of those and get them reviewed quite quickly because at the end of the day, the efficacy is messaging is the same as just how we've presented it.

[00:36:53] So validate the evidence once and then review the wording and context that's set around that when we're using different wording for different audiences.

[00:37:02] So this idea of we've added iterative submissions and series fees and also the introduction of modular content.

[00:37:11] So the ability to kind of stack and play with your key messages so that you can really respond to the feedback you're getting from the market.

[00:37:20] So if your sales reps are saying, you know, this particular pocket of doctors only wants to hear about these two particular endpoints, then you can build out pieces for that market that speak to those two particular endpoints.

[00:37:32] The claims would be pre-reviewed and approved as part of your modular library.

[00:37:35] And then at that point, you do a modular submission and it would have a much quicker turnaround.

[00:37:40] And often we'd expect that there shouldn't be many, many comments.

[00:37:45] So the process or time to approval will be much quicker.

[00:37:50] So we can say that we have one company that's already created a modular submission, a modular library and submission.

[00:37:58] And they did their first round of submissions to us.

[00:38:01] And they said they were delightfully surprised that the first round of comments were provide French and provide layout.

[00:38:08] Amazing. Love it.

[00:38:09] So to not have any comments for them was, you know, that's exactly what they wanted out of this submission.

[00:38:17] A quick turnaround, no rejigging of any content and they could get it.

[00:38:23] Now they appreciate that's not going to be everyone because sometimes headlines aren't approved or the way in which they stack it might not be acceptable.

[00:38:29] But their experience here was it really did reduce time.

[00:38:33] They could get those out into the field quite quickly and adapt and respond to the feedback they were getting from the field forces on a much quicker and more tailored and focused manner than maybe what would have been perceived in the past.

[00:38:47] So those are, you know, the structural things that we've done to try and be able to accommodate for any sort of influx that might happen over the coming years.

[00:39:01] As you know, how can you have a podcast in 2024 without talking about AI?

[00:39:08] So this, you know, this fear of, hey, with AI, we can build out copious amounts of content, but how is it going to get approved?

[00:39:15] If the approval process takes a really long time, then you're not being reactive.

[00:39:20] These are manners in which we can really reduce that approval time, streamline things so that if there is an influx in volume because of new content creation or scope change and focus or tailoring to different audiences and markets and ways in which people want to be spoken to, that we can still accommodate that volume as it comes in.

[00:39:44] There's not a ton of folks that I'm talking to that have really sort of stood up Gen AI at scale within their organizations in such a way that they've radically reduced the amount of friction that it takes to get finely tailored and tuned outputs created at scale.

[00:40:05] But that's not far away.

[00:40:08] And so the fact that you're not in a position where you're starting to see these submissions that have just tons more assets in them than in the past and then trying to scramble to figure something out.

[00:40:19] Like you, it feels like you've anticipated and the intent is that you are, you're ready for what is likely about to happen, whether that happens in Q1 of 2025 or Q4, Q1 of 2026.

[00:40:32] Like it's, it will happen as the industry's capabilities scale up, but you guys have tried to get ahead of it a little bit.

[00:40:37] Yeah, that's exactly it.

[00:40:38] And by no means are we like, and we're done now.

[00:40:41] That's all we have to do.

[00:40:43] You know, the modular submissions, it's going to be a learning curve for the first little bit as we, as people start to put them together and as we review the outputs of them and stuff.

[00:40:52] But we do feel like right now we have a really solid foundation to be able to make those changes and scales and really move with industry and not behind industry.

[00:41:05] If somebody's listening to this podcast and is inspired to engage with PAB in a different way or sort of re-engage with PAB in a different way and say, listen, you know, I want to get in touch with these guys and chat about how we're working together.

[00:41:20] Make sure that the team is trained up as much as possible.

[00:41:23] Who do they reach out to?

[00:41:24] Like where, where does someone go from here to continue or accelerate the conversation around a partnership with PAB?

[00:41:33] Yeah, so I mean, any number of people in that if you send anything to info at PAB.ca, you're going to get a response and the admin will make sure that it goes to the right person.

[00:41:44] So that can be your immediate default.

[00:41:46] Like if I don't know who to go to or where else to go, info at PAB will make sure it gets to the right person.

[00:41:53] Outside of that, you know, if you're not registered for the PAB form, I would say register there.

[00:41:59] It's a space where people ask general questions.

[00:42:02] And we provide general answers.

[00:42:05] It's where we post our newsletters and any updates for, you know, if we're looking for people for a committee or if we've got committee updates.

[00:42:14] Right now we have, as you mentioned, an AI working group.

[00:42:18] That's not specific to PAB interactions.

[00:42:20] It's really more of a content creation, marketing and regulatory across all of pharma.

[00:42:26] And PAB is just creating that space for those experts in their organizations to all come together and talk about some of the key challenges and brainstorm, you know, best practices.

[00:42:37] And what the future is going to look like and how we can all get there in a successful manner.

[00:42:43] We have a creative committee, but we're always looking to, you know, if there's a need, we'll try to create this space.

[00:42:51] So the creative committee came out of a push from industry to say, hey, we need better understanding around creative and we need to know if there's room for a little bit more leniency in how creative is interpreted.

[00:43:06] And so the creative group came together over that.

[00:43:09] You'll probably see some documents being posted shortly for consultation.

[00:43:13] So keep your eyes open for that.

[00:43:15] If you're not registered on our newsletter, that's a good way to also stay informed.

[00:43:21] And then if you're looking for training, you can reach out to myself or you can reach out to info at PAB training.

[00:43:27] We have a lot of different offerings if you're looking to get yourself up to speed, get your team up to speed.

[00:43:32] So whether that's in-house training or we have online courses that are broke down to be, again, micro training.

[00:43:40] That idea of we're not going to throw the entire code at you in one, two hour session and hope that you like leave knowing everything we've discussed.

[00:43:50] But really breaking it down into, you know, three to ten.

[00:43:54] And I think there might be one that's 12 minutes videos that allow you to really focus on a topic and then read the documents, compare, you know, learn at your own kind of self-directed pace.

[00:44:06] That's a new offering that we have that is a positive result of the pandemic where we couldn't do in-person training.

[00:44:14] So we had to do all virtual training, but really good, good ways to either familiarize yourself with the code or become re-familiarized with the code.

[00:44:24] Keep your knowledge and skill set up to date.

[00:44:27] And then we have the national workshops that happen once a year.

[00:44:30] So those are coming up in November and there'll be one in Montreal and one in Toronto.

[00:44:36] I appreciate you coming on this morning and taking the time.

[00:44:38] You probably have like a backlog of things that you need to now go and review, but it's always a lot of fun chatting with you, Jen.

[00:44:45] I really enjoy it.

[00:44:46] So thanks again for coming on this morning.

[00:44:47] Thanks so much for having me.

[00:44:48] It's been an absolute pleasure.

[00:44:50] Always love catching up with you.

[00:44:54] Thanks for listening all the way to the end.

[00:44:56] I hope you enjoyed today's episode.

[00:44:58] If you did, please take a moment to rate the show on whatever platform you're listening on.

[00:45:02] It means a lot to us.

[00:45:04] It also means a lot when we hear directly from you.

[00:45:07] So if you have thoughts on a future guest, suggestions on how to improve the show,

[00:45:11] or you just want to fill in some time in your day by sending me an email,

[00:45:15] you can reach me at neil at pharmabrands.ca.

[00:45:18] And a plug for our upcoming conference, Creativity Now, which is being held in Toronto on November 26th.

[00:45:24] As of today's recording, we have all of four tickets left to the event.

[00:45:29] So if you were thinking of joining, I'd suggest you head over to pharmabrands.ca

[00:45:33] and get your ticket before we're sold out.

[00:45:35] And one last thanks to NFA Health for making this episode possible.

[00:45:39] We'll see you all again in two weeks.