Pharmaceutical companies are struggling to reconcile online marketing techniques with a stepped-up oversight campaign by the Food and Drug Administration's Division of Drug Marketing, Advertising and Communications (DDMAC), which is specifically targeting such activities.
While industry-regulatory give and take on marketing is a long-standing and complicated dance, recent events appear to have caused pharma companies to take a step back from several strategies – at least until they can be sure they are compliant with FDA regulations.
On March 26, DDMAC sent warning letters to 14 major pharmaceutical manufacturers stating that the sponsored link advertisements for specific drugs were misleading because risk information associated with the use of the drugs was not included.
According to a study by comScore, several of these firms temporarily removed their sponsored link ads for the identified brands - as well as many other brands not specifically mentioned in the letters.
The letters, however, had an even wider impact and affected unbranded and vanity sites, even though these advertising methods were not specifically cited in the FDA letters.
The greatest pullback, though, was in sponsored ads, which registered substantial declines immediately following the letters, dropping 59% from 10.5 million during the week ended March 29 , to 4.3 million during the week ended April 5. Declines in sponsored link exposures continued over the next several months, plummeting 84% overall from March to June.
Unbranded web sites – sites that give information on a condition but do not endorse a brand drug - declined 35% from March to June to slightly more than one million exposures. Vanity URLs, which generically describe a health condition and then redirect to a specific brand drug’s website, declined 11% in June to 3.2 million average exposures vs. March.
March was perhaps a high point for FDA enforcement activity, but it was by no means an anomaly. FDA warnings to drug companies over misleading advertisements are stepping up, DDMAC Director Thomas Abrams said at the Food and Drug Law Institute’s 21st annual Advertising & Promotion Conference earlier this year. The division issued 33 warning and untitled letters for direct-to-consumer advertising from Jan. 1 through Sept. 15, more than half as many as in all of calendar 2008, he said.
Pharma companies' recent reticence to use sponsored ads in the wake of the March FDA letters is not likely to last indefinitely, however, especially in light of the numbers of people flocking to the web for medical information.
According to a recent study by the Pew Internet & American Life Project, a majority (61%) of people surveyed reported they look online for health advice, up from just 25% in 2000.
Another indicator of growing use of social media in a medical environment comes from recent analysis by Ed Bennett, who maintains a site devoted to social media use by hospitals. Bennett found a total of 367 US hospitals now using one or more social media tools to reach patients and other stakeholders.
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