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Change is a difficult call

The latest restrictions on doctor 'call-backs' will have far reaching consequences

It is highly possible that many current marketing plans are now in breach of the Association of the British Pharmaceutical Industry (ABPI) Code of Practice. This is because the rules governing rep call rates may just have been fundamentally re-interpreted by the Prescription Medicines Code of Practice Authority (PMCPA).

This rethink could have far-reaching consequences for the unwary marketer and it will also cause significant headaches for those who design and approve bonus schemes for sales reps.

There will be nowhere to hide for firms that try to bypass the rules, because it seems as though our customers - and also our own reps - will be watching us very closely in this regard.

What has changed?
We all know that a rep can make three unsolicited calls on a doctor in a given year. However, we also all know that the more times a doctor is exposed to our brand messages, the greater the chance of them prescribing the product.

Not all doctors respond in the same way, so most of us apply the Pareto principle and establish target doctor lists to ensure that our own activities and that of our reps are focused on those customers who will yield the greatest return for us.

This has led to a variety of schemes relating to rep call frequency as firms sought ways to justify more than three calls per year on target doctors. The result: both customers and reps are now expressing concern about some of these schemes and the PMCPA, which monitors the Code for the ABPI, has been forced to act.

The PMCPA clarification on this can be found on the cover-pages of its latest quarterly report, however these simple statements will have a big impact on the way some companies operate. This is not a new clause or ruling, just a restatement (reinterpretation, if you will) of the Code's existing wording.

Put simply, the PMCPA has now banned the inclusion of 'call-backs' in any rep bonus scheme. This means that any bonus scheme which encourages reps to make more than three 1:1 calls to an individual doctor is in breach of the Code.

It is acceptable for a rep to achieve a 'contact rate' above three because the PMCPA has recognised that the number of overall 'contacts' with a customer will include interactions at meetings and call-backs. However, firms cannot set a contact target for reps that includes call-backs.

So what does this mean in practice? First, consider a very simple target list of 10 doctors. The maximum number of calls we can instruct a rep to make on each person in this list is three. If we want to ensure each customer has monthly exposure to our brand we now have to employ different aspects of the marketing mix or more creative thinking.

We could increase the number of meetings the reps run or sponsor, although that has obvious implications for the promotional budget. We could also reserve more advertising space or send more mailings.

The limitations on the way we use reps does not just stop with call-backs, either. There is another fundamental principle which applies to call frequency objectives - that of reasonable probability. Essentially, it is unlikely that every doctor on a target list is accessible in a 1:1 call for the full three times in any given 12 months.

A call rate of three set against every doctor on our target list is not acceptable under the Code. Neither is a total call volume of 30 for a list of 10 doctors. This is because if a doctor refuses to see the rep, the only way to achieve the volume target is to call on one of the other named targets more than three times. This would effectively be a breach of the Code.

The same principle applies when we set daily call rates. We have to ensure that the territory is large enough for the rep to achieve the total number of calls each year without calling on a doctor more than three times. In other words, working on the assumption that there are 200 working days in the year, then each territory has to contain at least 200 doctors who are each willing to see that rep three times in the 12 months.

Marketers will have to apply some statistical thinking to determine how many GPs will have to be in each
territory to make the total expected volume of calls a `realistic probability' for each and every rep.

Either the daily call rates for each territory will be different, or the size of some territories may have to increase significantly. Remember that the Walsh average is just that - an average. If some reps struggle to hit the average, the Code effectively now prevents companies from holding back their bonus unless they can prove that the call rate is achievable for their individual patch. Otherwise the firm will have breached the Code because the call rate was not 'realistic'.

We should not forget that these comments on call frequency no longer just apply to doctors. They also apply to every prescriber, so companies now need to have individual call records for every nurse and pharmacist too - since the list of healthcare professionals (HCPs) who can prescribe changes almost daily, it is only prudent to assume that every HCP is a potential prescriber.

The burden of proof lies with the pharma company, not with the PMCPA. If the PMCPA has a reason to investigate how a particular company operates its call frequency schemes, then, as we know, the company is obliged to provide them with all relevant information. This could include the number of calls made against a named doctor over a given time period by a named rep (or any rep).

It also means companies have to keep detailed records, not just of the number of calls, but also of the type of call (ie, whether it was solicited or unsolicited).

One other challenge to consider is that the three unsolicited calls are an annual allocation, so when we calculate the requirements for each promotional cycle we need to bear in mind the annual call frequency this translates to. This is because there is a piece of supplementary information supporting clause 15.4 of the Code which states that the time intervals between calls also need to be considered when determining frequency.

In other words, if a rep is asked to make three unsolicited calls in the first three months, the PMCPA could choose to interpret this activity as an indication that the rep would be expected to make 12 unsolicited calls in 12 months.

So now another dilemma - do we weight the call allocations at the beginning of the financial year or do we spread the calls? Depending on specific needs, either option could serve. However, changing the target list midway through the year could result in some key customers not receiving any service from the local representative for subsequent cycles.

Different approach
Of course, there are still a variety of ways a company can achieve its marketing-driven contact objectives with target customers. In fact we have to find ways simply so that our business can thrive. For example, we could all operate dual salesforces which swap target lists after six months.

We could also investigate options for operating more flexible salesforces, with more reps employed in cycle one and fewer employed later in the year.

We need to be careful, though. Customers have been complaining increasingly about overcalling and now reps are expressing their concerns too.

The Code of Practice Review, for example, saw a case where a customer felt so passionately about this subject that he complained to the PMCPA that one firm had sent its reps into his place of business every week.

The fact that his place of work was covered by a number of reps from that company, and that he personally had not been seen during a 1:1 call was irrelevant; he was effectively complaining that the branding was too prominent on his unit and that reps were trying to see him and his colleagues too often.

Two of other cases in the latest PMCPA report, also related to call frequency concerns, were raised by sales reps.

Worryingly, the picture is emerging that some reps do not have confidence in their managers and are bypassing them and raising concerns directly with the authority.

This has implications for HR grievance procedures, as well as simply for our own marketing plans. As marketers, we need to consider the feedback from all of our customers, so maybe the messages we receive about call frequency will resonate in an unexpected way and force us to find new and more effective channels for communication with our customers.

Steven Gray, Steven Gray Consulting

12th February 2007


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