Healthy Skepticism Library item: 15488

Warning: This library includes all items relevant to health product marketing that we are aware of regardless of quality. Often we do not agree with all or part of the contents.

Publication type: news

FDA Letters Imperil Key Relationship Marketing Tactic
Pharma Live 2009 Apr 16
http://pharmalive.com/news/index.cfm?articleID=619208

Abstract:

FDA LETTERS HOBBLE A FAVORITE RELATIONSHIP MARKETING TACTIC OF TGAS® ADVISORS BENCHMARK COMPANIES

Full text:

The recent FDA letters on paid search listings raise major issues for pharmaceutical marketing programs, according to Donna Wray, Director and Management Advisor, Internet and Relationship Marketing Practice, at TGaS® Advisors. Wray polled TGaS Advisors Internet Benchmark clients on how their medical/regulatory/legal teams are interpreting the letters, seen as de facto guidelines for cyberspace promotion.

Wray found general, if unhappy, agreement among top-tier pharma clients that paid promotion through search engines must now be either 1) a reminder, which would include the full name of the drug product with no indication of therapy area, or 2) indication of the therapy area with no mention of the brand name. Using both in the same ad would mean having to include risk information and other “fair balance,” which will not fit in a 90-character ad. Companies also concurred that the effect of these letters is likely to be limited to paid search. Changes are not expected for organic search listings, for example.

Before this ruling, paid search was one of the most efficient ways for companies to obtain quality leads, according to Wray. Paid search was a primary source of enrollments for relationship marketing programs – more than doctor’s office brochures or television. A single brand’s average spend in this category was a little over $1 million per year, which delivered ads to more than 300 million people via search engines. TGaS Advisors will track the impact of these rulings on benchmark members over time, but Wray expects that amount to drop to a fraction and the category to go from “must have” to “also ran” for most brands. Not only will fewer ads be placed, but the new restrictions will mean fewer clicks for those that are.

“I understand the regulatory concerns,” said Wray, “but unfortunately, this new limitation in paid search advertising does a disservice to patients. If you are diagnosed with a serious condition, you will have difficulty finding information on the newest drug treatments. On the other hand, you’ll have no trouble locating untested herbal remedies, supplements and gadgets whose producers are free to make outrageous claims because they operate outside the FDA’s jurisdiction.”