From key opinion leaders to influencers: Rethinking Fair Market Value in the modern healthcare industry

Why this topic now: digital engagement is no longer an option but rather another channel alongside conventional outreach programmes

Life sciences and healthcare organisations are increasingly engaging stakeholders through digital platforms - social media, community forums, virtual events, and hybrid scientific exchanges. Industry guidance has evolved to clarify that digital channels are broadly defined and that existing legislation and codes apply equally to communications in these environments.

At the same time, the who of influence is broadening. DOLs can include not only well-known physicians but also patients, patient advocates, and other voices who shape discourse and behaviour online.

This creates opportunity and risk. The opportunity is more timely, scalable education and dialogue. The risk is that compensation models designed for traditional, time-bounded HCP services are being applied inconsistently to digital activities - or replaced with influencer-style constructs that can be difficult to defend.

Defining DOLs in a way that support a global FMV approach

For purposes of this paper, a DOL is any individual who:

• has recognised credibility or lived experience in a health topic area, and
• uses digital channels to educate, discuss, or convene an audience, and
• may be engaged by organisations for specific, documented services (e.g., content creation, advisory input, moderated dialogue).

This definition is intentionally broad because DOLs can include HCPs as well as patients and advocates.

Key implication

A global FMV model must be role- and service-based, not title-based. In other words, the FMV question is not “Is this person influential?” It is, “What services are they providing, how much time/effort will it take, and what is a reasonable FMV for that service in that market?”

The core risk: when digital creates a second (and weaker) compensation logic

In many organisations, conventional HCP FMV approaches are relatively mature for activities like advisory boards, speaker programmes, and consulting. Digital engagement, however, introduces work types that are:

• asynchronous (e.g., responding to questions over a 2-week window),
• iterative (multiple rounds of content review),
• multi-format (short videos, live streams, threaded discussions),
• more persistent (content can live indefinitely and be reused).

Without clear scoping and valuation, organisations may drift into problematic patterns such as:

• paying for influence signals (followers, engagement rates),
• inconsistent rates by platform rather than by service,
• unclear deliverables and weak documentation,
• gaps in monitoring and moderation responsibilities - despite guidance that companies are accountable for content they initiate, brand, or sponsor (including through third parties acting on their behalf).

Our point of view: one FMV spine for HCPs and DOLs, plus digital add-ons

The FMV spine (applies to both conventional HCP and DOL services)

A global, defensible FMV method should consistently anchor compensation to:

1. Bona fide service need (why this person, why now, why this service) and documented rationale for engagement.
2. Time and effort (including prep, participation, and post-activity requirements).
3. Expertise and complexity (topic complexity, credentials, and role expectations).
4. Defined deliverables (what is produced, quality expectations, review cycles).
5. Appropriate methodology for determining rates, including for online influencers/DOLs.

This is aligned to the principle that HCPs should be fairly compensated for expertise and services at FMV.

Digital add-ons (what digital changes)

Digital work often includes additional, measurable effort that should be explicitly scoped and valued - without turning compensation into an influence premium. Examples include:

• Content production effort: scripting, recording, editing, accessibility requirements, and multiple review rounds.
• Asynchronous engagement windows: time-boxed Q&A participation, follow-up responses, moderation coordination.
• Compliance and process overhead: required training, disclosures, content routing, and monitoring expectations; guidance emphasises robust procedures for reviewing/monitoring digital activities and moderating inappropriate comments in a timely manner.
• Transparency requirements: clear disclaimers attached to DOL/influencer posts to identify company involvement.

Bottom line: Pay for the work and documented service need using the traditional FMV spine andadd FMV only for additional digital effort where it exists.

Transparency and transfer of value: designing for a multi-country reality

A global paper must acknowledge that transparency regimes differ by market, but several global design principles travel well:

• Design for traceability: treat DOL/HCP engagements as reportable relationships where applicable, with consistent data capture.
• Expect disclosure obligations in many markets: disclosure of transfers of value (ToVs) from member companies to HCPs/HCOs/POs; disclosure is generally individual, with certain allowances (e.g., aggregate for R&D or when consent is not obtained).
• Keep the story simple: services rendered → FMV rationale → documentation → transparency reporting where required.

This is another reason to avoid influence as a compensation driver: it is harder to explain, harder to document, and more likely to be questioned across jurisdictions.