Pharma Goes Online; Feds Fail to Follow

While the fiercest opposition to direct-to-consumer (DTC) advertisements has been to television advertisements, pharmaceutical companies have increasingly turned their attention to online marketing and social media, such as Facebook and YouTube with very little opposition or regulation by the Food and Drug Administration. In this report, CHW explores the reasons for this increased use of online marketing and social media, profiles a few recent examples where online DTC advertisements have raised concerns, and suggest possible future directions for consumer advocates.

Since the Food and Drug Administration (FDA) first relaxed guidelines governing direct-to-consumer (DTC) pharmaceutical advertising in 1997, DTC advertising has increased dramatically, from approximately $1 billion per year in 19971 to $5.4 billion in 2006.2 As a result, physician and advocacy groups and some elected officials have begun to raise questions about the ethics of DTC advertising.3 While the fiercest opposition to DTC advertisements has been to television advertisements, with less opposition, pharmaceutical companies have increasingly turned their attention to online marketing and social media, such as Facebook, YouTube, Sermo (for physicians), and iVillage (for women’s health).4 A recent article in Advertising Age notes that “what might be considered a yawn-worthy move into new and social media is nothing short of a revolution” for the pharmaceutical industry.5 In this report, Corporations and Health Watch explores the reasons for this increased use of online marketing and social media, profiles a few recent examples where online DTC advertisements have raised concerns, and suggest possible future directions for consumer advocates.

Online advertisements and social media challenge our conceptions of DTC advertisements

Some of the largest pharmaceutical companies have challenged common conceptions of DTC communication through the launch of popular blogs, YouTube channels and other forms of online media. For example, Johnson & Johnson’s McNeil Pediatrics unit sponsors an attention-deficit hyperactivity disorder group called “ADHD Moms” on the social media site Facebook,6 where the number of participants has grown to more than 8,200 without any expenditure by the company.1 Johnson & Johnson also hosts a popular blog called “JNJ BTW” where the company seeks to create a space for a “three-dimensional view” of the company and a “conversation” with consumers. Novartis, Boehringer Ingelheim and AstraZeneca all use Twitter to deliver news about their companies, and several firms have launched controversial channels on YouTube to promote their drugs. Pharmaceutical companies also bid for key words such as “cholesterol” in Google and other search engines so that advertisements for their drugs will appear in the sponsored search results, for which the search engine company collects a fee each time someone clicks on the advertisement.7 In addition, contextual advertising on websites offers pharmaceutical companies the opportunity to place banners on websites targeted to visitors to certain websites or to visitors in certain geographic locations.7

Reasons for industry’s increased use of social media and online advertisements

At a time when print advertisements for pharmaceuticals are down 18% and television advertisements are down 4% to $4.4 billion in 2008 (compared to the $4.8 billion spent in 2007),1 online marketing efforts have soared.1, 5 One reason drug makers have turned to online advertising is because it is a relatively inexpensive way to reach targeted audiences. But in addition to being cost-effective, online media communications are less likely to mobilize patient advocates who are critical of DTC advertising.4, 7

Some observers have suggested that the “lower profile” yet highly effective online DTC advertisements might be “simply smart politics” on the part of pharmaceutical companies wishing to avoid attention by members of congress who wish to regulate DTC advertisements.2 Pharmaceutical marketers have taken advantage of the fact that greater numbers of Americans are now seeking health information and support online instead of consulting their physicians.4, 5, 8 Patients are now seeking more interactive communications, and, in an interview with Advertising Age, a relationship-marketing agency CEO said that social media offers the pharmaceutical industry an opportunity to rebuild trust between the consumer and an industry that is often unpopular.5

Recent DTC “success stories”

Several pharmaceutical companies have launched highly successful online marketing communications, and in some ways these companies serve as industry forerunners.5 Here are some examples:

MULTIPLE SCLEROSIS: Patients with chronic conditions often turn to the internet for the support of others with similar concerns and for help in managing chronic conditions.4 Acorda Therapeutics, working with a division of global advertising agency Saatchi & Saatchi launched a community website called iwalkbecause.org in advance of the release of its drug for multiple sclerosis which will not be available until next year.5 According to a Saatchi executive, the community of people with multiple sclerosis is a group that searches for online information “ferociously.” 5

AMBIEN CR: Saatchi also worked on an integrated TV-web campaign for Sanofi-Aventis’ sleep drug Ambien CR.5 The 15-second commercial directed viewers to go to a “microsite” called silenceyourrooster.com with games, videos, and other social-media elements.5 In the first three days, the site received 1 million “hits” and a 2% “clickthrough rate” to the branded site www.ambiencr.com.5

ASTHMA: AstraZeneca launched a YouTube channel called “My Asthma Story” for its asthma drug Symbicort where they invite patients to submit videos about their positive experiences with Symbicort to their website, where consumers “essentially create their own advertisements for the drug.”5

RESTLESS LEGS: In late 2006, GlaxoSmithKline introduced an unbranded and very creative video on YouTube that received over 200,000 views, which led the company to establish its own YouTube channel, GSK Vision.5

Future Issues for advocates and regulators to consider

Overall, the FDA has, until recently, been weak in its response to pharmaceutical companies’ online DTC advertisements. In fact, there are no published guidelines for online pharmaceutical advertising by the FDA Division of Drug Marketing, Advertising, and Communications Research, the organization typically responsible for providing such oversight.5 As noted by a senior VP at the public relations and marketing communications firm Fleishman Hillard, “People are still figuring out how we employ new media, whish is such a completely new paradigm. What [pharmaceutical companies] are doing now is experimenting.” 5 Similarly, Symbicort brand manager for AstraZeneca notes, “The social-media space is still very much a gray area.” 5 Without oversight, controversy has begun to erupt as it did this past January, when a banner ad went online for the emergency contraceptive Plan B. Plan B is marketed by Duramed, a subsidiary of Barr Pharmaceuticals, which was recently acquired by Teva Pharmaceuticals USA.9 The company advertised on the MTV website which is very popular among girls 17 and younger, directing viewers to go to the Plan B website with the tagline “Because the unexpected happens.” 9

Last April, the FDA began to take action with regard to DTC advertising in new media by sending major pharmaceutical companies untitled letters in April asking them to not place misleading ads on search engines such as Google and Yahoo,5 as well as taking action regarding several YouTube videos with misleading pharmaceutical advertising content. For example, the FDA requested that UK drugmaker Shire Pharmaceuticals remove its YouTube video for Adderall XR, which the agency argued was overstating the hyperactivity drug’s effectiveness while omitting relevant information about risks.10 The FDA also began requiring pharmaceutical companies to embed safety and risk information in the videos themselves, rather than providing a link alongside the video advertisements they post.10

As pharmaceutical companies increasingly turn to online media and social marketing to reach consumers, regulatory guidance from the FDA on this “gray area” will be increasingly necessary, as will increased vigilance on the part of consumer advocates and Congressional leaders.

References

1 US DTC Rx advertising falls 8% to $4.4 billion. Pharma Marketletter. April 21, 2009.

2 US Pharma DTC “recession” started in 2006. Pharma Marketletter. December 5, 2008.

3 Douglas J. Wood Reed Smith LLP. Legal issues to watch in 2009. Advertising Age. December 15, 2009.

4 US drugmakers switch marketing approach. Pharma Marketletter. April 25, 2008.

5 Miley M, Thomaselli R. Big Pharma finally taking steps to reach patients with digital media: highly regulated industry slowly mobilizes with blogs, Twitter, YouTube. Advertising Age. May 11, 2009.

6 McNeil Pediatrics, ADHD Moms A Place for Moms of Children with ADHD. Press Release dated July 9, 2008. Available at: http://www.mcneilpediatrics.net/mcneilpediatrics/assets/
60CON08453A_ADHD_Moms_Press_Release_FINAL_FOR_DIST.pdf

7 US drug DTC cuts in 1st half 2008: TV ad effectiveness low, regulatory risk high? Pharma Marketletter. October 17, 2008.

8 California HealthCare Foundation. Social Media’s Challenge to Traditional Health Care Patients, Providers, Researchers, and Advocates Forge Online Connections. April 22, 2008. Accessed June 7, 2009 at: http://www.chcf.org/press/view.cfm?itemID=133633.

9 Thomaselli R. “Morning-After Pill” catches flak for MTV.com ad: site’s under-18 visitors will see banner for emergency contraceptive Plan B. Advertising Age. January 8, 2009.

10 US FDA swoops on YouTube “DTC Abuse.” Pharma Marketletter. December 4, 2008.

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