Hour-by-Hour Action Plan
Key Priorities: Patient safety, regulatory compliance, ethical transparency, financial stability, and stakeholder trust.
First 24 Hours: Crisis Assessment & Preparation
Hour 0–2 (Immediate Response):
- Convene a cross-functional crisis team (Chief Medical Officer, General Counsel, Chief Compliance Officer, CFO, Head of Communications, Head of Regulatory Affairs).
- Reasoning: Ensure alignment on facts, risks, and strategy. Legal and compliance teams will outline reporting obligations; medical team will validate the risk severity.
- Lock down internal communications to prevent leaks.
- Reasoning: Avoid premature market panic or misinformation.
Hour 3–5:
- Engage external independent experts (e.g., hepatologists, pharmacovigilance specialists) to validate the findings.
- Reasoning: Independent verification strengthens credibility and informs regulatory/legal strategy.
- Draft preliminary regulatory filings (e.g., FDA Adverse Event Reporting System) with legal oversight.
- Reasoning: Accelerate the 6-month timeline by pre-preparing documentation.
Hour 6–8:
- Scenario-planning with CFO and Investor Relations:
- Model financial impacts of disclosure (e.g., stock drop, litigation costs).
- Prepare messaging for earnings call that balances transparency with reassurance (e.g., highlighting other pipeline assets).
- Reasoning: Mitigate investor panic while upholding ethical obligations.
Hour 9–12:
- Develop patient safety action plan:
- Immediate update to drug labeling and prescriber warnings via “Dear Healthcare Provider” letters.
- Launch a patient notification system (e.g., pharmacy alerts, website updates).
- Reasoning: Proactive risk mitigation reduces liability and demonstrates ethical responsibility.
Hour 13–18:
- PR/Comms Strategy Session:
- Draft press releases, FAQs, and internal talking points.
- Emphasize patient safety, transparency, and commitment to solutions.
- Reasoning: Controlled messaging prevents speculation and maintains trust.
Hour 19–24:
- Pre-Board Meeting Briefings:
- Share crisis team findings and recommendations with key board members individually.
- Advocate for immediate disclosure, emphasizing long-term reputational/legal risks of delay.
- Reasoning: Pre-meeting alignment reduces boardroom conflict and ensures unified messaging.
Next 24 Hours: Execution & Communication
Hour 25–30:
- Board Meeting:
- Present validated data, external expert opinions, and recommended actions.
- Overrule “wait for data” push by framing delay as existential risk (legal, regulatory, reputational).
- Vote to approve immediate disclosure and patient safety measures.
- Reasoning: Ethical leadership requires prioritizing patient welfare over short-term financial concerns.
Hour 31–36:
- Regulatory Submission:
- File preliminary reports with regulators (FDA, EMA, etc.), flagging urgency.
- Request expedited review given public health implications.
- Reasoning: Demonstrates compliance and builds regulatory goodwill.
Hour 37–42:
- Internal Communications:
- Host all-hands meeting to inform employees, emphasizing company values and patient-first ethos.
- Reasoning: Maintain morale and prevent internal dissent/leaks.
Hour 43–48:
- Public Disclosure & Earnings Call Prep:
- Issue press release and host media briefing:
- Acknowledge the issue, apologize, detail patient safety steps.
- Highlight ongoing research and support for affected patients.
- Finalize earnings call script:
- Briefly address the issue but focus on financial resilience (e.g., cash reserves, diversified portfolio).
- Reasoning: Transparent public communication limits reputational damage; earnings call reassures investors.
Critical Decisions & Rationale
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Immediate Disclosure Over Delay:
- Why: Waiting risks regulatory penalties, catastrophic lawsuits, and irreparable trust loss. A 40% stock drop is reversible; bankruptcy from litigation is not.
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Patient Safety First:
- Why: Proactive warnings and provider alerts reduce harm and liability. Ethically, patients deserve informed consent.
-
Earnings Call Strategy:
- Why: Acknowledge the issue without oversharing unvalidated data. Reaffirm financial stability to prevent panic selling.
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Board Management:
- Why: Pre-meeting lobbying ensures alignment. CEOs must lead, not defer to short-term board pressures.
Post-48-Hour Next Steps
- 72 Hours (Earnings Call): Stick to pre-approved messaging; defer detailed questions to pending investigations.
- Week 1: Launch patient support programs (e.g., liver monitoring subsidies).
- Month 1: Begin settlement negotiations for potential litigation and explore insurance coverage.
Final Note: This approach balances ethical rigor with strategic pragmatism, safeguarding lives while preserving the company’s viability. Transparency is the only sustainable path forward.