Last week the U.S. Food and Drug Administration wagged its finger at more than a dozen pharmaceutical companies over their use of paid search advertising.
In one day, the agency sent an unheard-of 14 warning letters to pharmaceutical companies regarding their use of search ads on behalf of more than 40 drugs. The list of brands mentioned included such top sellers as Lexapro (an antidepressant) and Plavix (a blood thinner). GlaxoSmithKline, Sanofi-Aventis, Merck, and Eli Lilly were among those to receive letters.
Industry observer Mark Senak said it looked like the FDA was trying to clean up pharmaceutical search engine marketing by playing “whack the mole” rather than issuing some regulatory guidance. But an FDA spokesperson said the agency found “a plethora of violations across all classes of drugs,” and noted the FDA’s policy is to enforce the same standards in all media.
The FDA letters accused drug companies of three main violations: First, the inclusion of information about what condition the drug was for, but not about its risks; second, not including the full pharmaceutical name (e.g., just “Celebrex” instead of “Celebrex (celecoxib)”; and third, not including details about its limits — for example, only effective for certain age groups, or only effective in conjunction with another drug.
So-called “reminder ads” — those that mention the drug without any other information (“Find out what Nexium can do for you!”) — are acceptable in search ads. But even reminder ads are prohibited for drugs that carry so-called black-box warnings, for serious or life-threatening side effects.
Meanwhile keyword searches for any of the offending drugs deliver the drug’s Web site at the top of organic results, along with just about the same amount and type of information the FDA objected to last week.
Several of the companies declined to comment; their responses to the FDA are due today. The offending ads for the cited drugs have disappeared for now. Google spokesperson Eric Obenzinger noted companies can change their campaigns on the fly.
Google itself isn’t getting involved. “The FDA letters are directed at pharmaceutical search advertisers,” he says. “Obviously, these warning letters will change the format of the sponsored links that people see next to organic search results.”
About 100 million people a year go to the Internet to do drug research, said Monique Levy, head of research at Manhattan Research , a New York-based pharmaceutical and healthcare research and services company. A search engine, and Google in particular, is where they’re likely to start, but it’s rarely where they stop. The drug companies’ assumption that people will click through to the fine print is well founded, Levy says.
“That’s why they thought they were OK,” she says. “Maybe some pharma companies were pushing the envelope, but I can’t think of another context where an ad is a keyword and a link with two lines of text. The FDA should start thinking about a more efficient way of addressing this problem.”
If pharma companies abandon sponsored links completely, they’ll cede the channel to generic competitors, online pharmacies of marginal legality, or lawyers handling class-action lawsuits against their products. But until drug marketers can twist those two-lines-and-a-link into something that can attract consumers while deflecting the wrath of the FDA, they may be more trouble than they’re worth.