POST SUMMARY: The idea that the reason for the decline in violation letters from the FDA is due to the FDA being afraid to take action in my opinion is very weak. Rather, I think it’s because both DTC marketers are playing it safe and cuts to FDA staff via budget tightening.
Can anyone really name one DTC campaign that featured really great innovative marketing? When was the last time a pharma brand won awards, from outside the industry, on DTC advertising?
Late last year I was going over some research results, from both Manhattan Research and qualitative research I led, with a biopharma marketing team. When we discussed the implications and opportunities a member of their MARCOM team said “we are not going to do anything too risky as we don’t want any violation letters from the FDA”. Everything that we proposed from a message board to a social media campaign so patients could share stories about living with MS was rejected even though research suggested they were key opportunities.
I would say that the reason for the decline in NOV letters is because both of the lack of really talented marketers and those in DTC who are afraid to rock the boat and just trying to fit in to hold their jobs. Courage is needed to blaze new trails….