Doc, I Need A Second Opinion About This Ad That I Saw

Today it is possible to create and run ads in a few hours. You can buy your own TV spot through Google to run a video you made with a $200 camera, or spend 20 minutes to set up a SEM campaign with a search engine or display campaign across an exchange.

For most marketers the only downside to our new rapid-response, multi-format ad world is the clutter that it has inevitably created. For health marketers, there is another downside: how to be nimble in a regulated industry.

Regardless of how you feel about regulation, what matters most at the end of the day is that products on the market are safe and effective in the bottle and that patients who will benefit most from them know about them. The key to making that happen is a regulatory process that can review ads and guide the marketing community to operate in a responsible and commercially sustainable fashion.

Enter the FDA's Division of Drug Marketing, Advertising, and Communications and the Center for Drug Evaluation and Research (CDER). Historically, this agency has been the only government agency responsible for reviewing and investigating prescription advertisements. Operating as a closed system limits the amount of material that can be reviewed. In a Web 2.0 world, we may need a Gov 2.0 approach to keeping up.



The answer: Crowdsource it! With a crowd of experts!

CDER recently announced the Truthful Prescription Drug Advertising and Promotion (also known much more memorably as: the Bad Ad Program!) Initially, the Bad Ad Program is rolling out to doctors to ask them to be more attentive to the marketing pitches they see and hear in professional settings like conferences. The program is actually much larger in scope and considers any advertisements doctors or their patients may see.

The math for review could become more favorable to the extent that docs who -- in the vernacular of Homeland Security -- "see something, say something."

It is not clear how much effort the FDA will put into encouraging participation, and it will take more than a Web site announcement to spark any meaningful activity. That said, the FDA should be applauded for opening up more of its processes which it itself has described as a "black box" in its Open Government Plan. Increasing the amount of participation and transparency will not only help us learn more about what responsible effective advertising is but, more importantly, could provide more direct and frequent feedback about ad creative that is considered "safe," thus taking some of the guesswork out of creative development.

What Should Doctors Look For?

The FDA has provided these red flags to look for when evaluating ads:

  • Omitting or downplaying of risk
  • Overstating effectiveness
  • Promoting off-label, or unapproved, uses
  • Misleading drug comparisons

The site provides a few examples of the kinds of claims that marketers may make that should be reported. There is a snappy email address -- -- they can use as well.

Some Advice to the FDA

Creating programs where responsibility and vigilance is shared is likely to improve the way the system works -- but why stop at docs?

Ordinary citizens raised on the Facebook "Like" button can be and probably want to be involved, and there are many more of them than there are doctors. Recall last December that several groups of students took on a challenge from Darpa, (the Defense Department's Defense Advanced Research Projects Agency) to find 10 red balloons launched around the country over a weekend. Many different strategies were employed -- all involved activating everyday people to look for these balloons. All 10 were found across the country before the weekend was over, and the program boasted 4,300 participants with less promotion than the Bad Ad Web site.

One prescription for ensuring "safe" pharmaceutical advertising may be more Gov 2.0 answers like the Bad Ad program to help solve Gov 1.0 challenges.

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