The online marketing wake-up call that the Food and Drug Administration sent in early April to 14 pharmaceutical companies — in the form of letters ordering them to change how they approach search-engine advertising — has altered how, and even whether, pharma companies use Google and Yahoo to reach potential customers. It has also shifted at least some pharma ad dollars over to specialty health portals where ad formats can more readily comply with the FDA’s strictures.
And after all the fuss, the amount and type of information that consumers can glean from search results on a particular drug is exactly the same.
The FDA letters, posted online April 3, went to many of the biggest names in pharma, including GlaxoSmithKline, Pfizer, and Johnson & Johnson. They cited search engine ads for 48 different drugs that violated at least one of three FDA guidelines that apply to drug advertising in all media:
- Including information about what condition the drug was for, but no information about its risks.
- Not including the full pharmaceutical name.
- Not including details about the drug’s limits — for example, only effective for certain age groups, or only effective in conjunction with another drug.
Because it’s difficult to cram the required information into the two lines of copy that paid search ads allow, pharma companies relied on a “one-click rule,” assuming that if the information was available on the very next screen by clicking on the link, they were okay. But there was no such rule, even though it took the FDA more than a decade to crack down. It’s still keeping advertisers guessing by not issuing guidelines for online pharma advertising. Blogger Mark Senak of Eye on FDA pointed out last week that the Federal Trade Commission issued online ad guidelines as early as 2000, and suggested that the FTC, not the FDA, should be overseeing direct-to-consumer drug ads.
Meanwhile, consumers who search Google using the names of specific drugs will find that:
- Some drugs, like Levitra and Lexapro, apparently no longer have paid ads appearing with a search on their name.
- Some drugs have a paid link to their official Web site, but no indication of what the drug is for.
- Some drugs have a paid link relating to the disease rather than the drug, but a click takes visitors to the drug’s “official” site. For example, www.SmokingCessationOption.com resolves to www.Chantix.com. With these types of ads, the link often leads to an interior page with full risk information, rather than to the home page.
That last strategy is Google’s concession to the pharma companies’ difficulties, since advertisers aren’t normally allowed such misdirection, says Mary Ann Belliveau, the company’s healthcare director. “It’s the only exception to our visible URL policy,” she says.
“We saw right away that a lot of campaigns were paused as companies changed creative or took down ads for a short time,” she adds. “We’ll do whatever we need to do to help our customers be compliant. We are looking potentially at enhancements to sponsored links that would allow for presentations that might be acceptable to the FDA,” though the company isn’t ready to announce anything.
At least some additional ad dollars have flowed to specialty portals like WebMD, which saw an 18 percent jump in ad revenue in the second quarter compared with last year, according to the earnings report released last week. During an earnings call, a Citigroup analyst queried WebMD CEO Wayne Gattinella about how the FDA action had affected business.
“We’re seeing major pharma brands beginning to shift dollars from many other venues, both offline and online, to our properties,” Gattinella said. “We are beginning to really penetrate some of the larger brands at a level we haven’t seen before. In terms of the new requirement to provide more information regarding patient safety, we quickly responded to that need by reengineering all of our display advertising in a way that could support these greater disclosures.” Some drug ads at WebMD have risk information built right into the banners in the form of scrolling text.
Healthline Networks, an ad network of 30 health-related sites, has doubled its revenue compared with the second quarter of 2008, though CEO West Shell says the FDA crackdown was only one contributing factor, along with an improving economy. “We’ve seen an increase in the size of the banner campaigns running across our network.” Healthline is developing a search engine marketing tool to help advertisers comply with FDA requirements, to launch later this year.
Ironically, if a customer searches on a drug’s name, natural search results will almost always put the “official” site at the top of the rankings, right along with whatever is in the title field and/or meta information of the site’s home page. Usually, that’s an indication of what the drug is for, with no indication of risks — exactly the combination of information and lack of information that the FDA finds troublesome.