Just how out of touch are DTC TV guidelines ?

iStock_000010822711XSmall_thumbIf the FDA wants to make DTC TV ads relevant to consumers they need to revisit the guidelines they established years ago.  For example, the requirement to add a “see our ad in…” is completely worthless.  Does the FDA really believe that consumers are going to remember that ?  Then there is the fair balance which is a bit of an oxymoron.  What the FDA really needs to do is look at how people are reacting to these ads and better understand the steps they go through as they decide on which drugs they are going to ask about.

If you‘re seeing a lot of drug ads on TV than you know that this is the time of year when most brands have to use it or lose it.  In fact Nielsen estimates an average of 80 drug ads air every hour of every day on American TV.  That’s a lot of ad dollars but what is missing is a keen understanding of how consumers decide to move from prospect to customer.  As a marketer, for example, I would want to know where consumers are dropping out in the healthcare transaction model and find ways to keep them engaged with the brand.

Too many marketers use the we’re a regulated industry” tag to keep their marketing stuck in the past.  However, the FDA has also done little to make drugs ads relevant to consumers.  For some reason they really believe that consumers are going to see an ad on TV and run to their doctor to ask for an RX.  We know that it doesn’t work like that any more.  What is even more absurd is the requirement to say “see our ads in…”.  What the hell good is that ?


I am not a believer in fair balance on TV ads and I really think that it should not be required on drug.com home pages.  What I would rather see is a simple, patient centered fair balance. Something that patients could easily understand and more importantly relate to as they go through the evaluation process of deciding if the drug is right for them.

I’m not sure the FDA really understands how patients use the Web for health but I am really sure that the current guidelines are out of date.

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