Will the FDA ever understand DTC advertising?

UnknownKEY TAKEAWAY: “Two things are infinite: the universe and human stupidity; and I’m not sure about the universe” said Albert Einstein.  I’m beginning to think that can be applied to the FDA when it comes to DTC ads.  Studying animation in DTC ads?  At a time when DTC ads are under attack the FDA should be reassuring attackers that DTC ads benefit consumers and doesn’t lead to patients requesting unnecessary prescriptions.

The reason I talk to myself is because I’m the only one whose answers I accept.  That’s the FDA in a nutshell.

For some unknown reason the FDA really believes that viewers are going to run to their doctor to ask for/about and advertised drug.  Note to FDA: that’s not happening.

Millennials, the generation between the ages of 18 and 34, do not visit doctors the way other age groups typically do, a growing body of evidence shows. Not only do they forgo healthcare in favor of other priorities, when they do need medical attention, they turn to Google and WebMD before visiting actual doctors, whom they are less like to visit repeatedly or regularly. Now here’s the key point: this is true across ALL generations.

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What the FDA should be asking is “what are viewers doing as result of seeing a DTC ad?” and “what are the top influencers that get patients to ask for an Rx?”  Of course, most of us know the answer to this question, patients are going online to learn more and pharma websites are not the top influence to ask for an Rx

The other side of this question is that for some health conditions patients will do more research and for some less.  I doubt, for example, that someone is going to spend half a day online researching toenail fungus, but they could spend several days online deciding if a treatment for irritable bowel is worth the benefit.

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Then there is fail balance. According to the FTC “when a space-constrained ad requires a disclosure, incorporate the disclosure into the ad whenever possible. However, when it is not possible to make a disclosure in a space-constrained ad, it may, under some circumstances, be acceptable to make the disclosure clearly and conspicuously on the page to which the ad links.” In other words the one-click rule can apply to the promotion of pharma products but only if the FDA agrees with the FTC.

I presented social media 101 to the FDA when social media was becoming a hot channel and to this day the FDA still has no idea how patients are using social media to make healthcare choices.

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The FDA needs to join the 21st century but more importantly, they can’t apply science to human behavior when it comes to marketing.  Patients are going online and not running to the doctor, blindly, to ask for advertising drugs.  It’s time for the FDA to learn this lesson and be proactive rather than reactive.

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