The FDA and Pharma Search Engine Marketing - Episode 32
Maureen Malloy, Marketing Manager
The search world has experienced a lot of action in the past few months – Microsoft launched Bing and also announced a search partnership with Yahoo – and both developments promise to shake up the landscape for 2010 and beyond. But the biggest event to rock the pharmaceutical world specifically occurred on April 2, 2009, when the U.S. Food and Drug Administration sent warning letters to fourteen major pharmaceutical companies, including Pfizer, GlaxoSmithKline, Johnson & Johnson, Sanofi-Aventis, and Merck. According to the FDA, the brands that were flagged all sponsored paid search advertising that violated drug marketing guidelines, particularly in three ways. Number 1: Lack of risk information – the violating ads discussed what the drugs treated but did not include risk information; Number 2: Failure to communicate indications – the violating ads failed to fully convey which types of patients or specific situations to which they’re limited. Number 3: Omission of established name – the violating ads didn’t list the drug’s established name in conjunction with the common name. For example, a search ad promoting the drug Cialis® now must include the generic name tadalafil – pretty tricky when search advertisers have ad real estate with which to work! Check out the warning letters yourself here (scroll down to "April 2009").
Many pharma execs and agencies were taken aback by the FDA’s action. The nature of paid search ads, as they are typically limited to less than 100 characters, for the most part prevent brands from featuring ad copy while also including full risk information and lengthy established names. Many campaigns followed the now-proven-false “one click rule,” which basically meant that marketers assumed their campaigns were FDA compliant if searchers could access full risk information within one click of the search listing. Many in pharma are at odds over the situation, claiming that the FDA lacks an understanding of digital media and best practices and that they’ve neglected to lay out adequate guidelines on how to leverage online marketing within the regulatory environment. The FDA, on the other hand, has defended the crackdown by noting that no form of media is immune to the regulations put in place for pharma drug advertising.
Despite the challenges the citations present, don’t expect pharma search engine marketing to disappear. Campaigns that were in violation halted for a short period while search teams scrambled to revise the offending ads, but for the most part they are back in action. Brands are hoping that even by separating the product and condition information, savvy consumers will link one to the other based on their query.
The reality is that searching is too ingrained in online health behavior to be ignored, and unlike some other types of promotion that “push” messages in front of the masses, search engines give marketers the opportunity to deliver relevant brand content to interested consumers at the moment they are seeking answers to health questions or problems. Close to 100 million consumers use the Internet to look up pharma information, and for many, search engines are a critical gateway to the plethora of websites, blogs, product reviews, message boards, wikis and the like. In lots of cases, paid search gives pharma brands the chance to compete for keywords that are dominated by sites like WebMD, Wikipedia, and even user-generated content, in organic results.
For now, count on brands to tread lightly when it comes to pharma search engine marketing – they will use search advertising to drive visitors to brand sites, but will be conservative with copy for the meantime. Hopefully pharma, agencies, the FDA, and the engines themselves will be able to collaborate on ways to make search an effective strategy for brands as well as a useful tool in leading consumers to pharmaceutical information online.
That concludes today’s podcast, and we thank you for joining us today.
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