WHAT’S UP?: It’s time to admit that the FDA is completely out of touch regarding DTC advertising. Fair balance is not being read in ads or listened to on TV, and the language used in fair balance is too often complicated for online health seekers.
I just finished an analysis of a pharma clients website using their analytics. Rather than just report the numbers my report “tells a story” that managers can use to justify changes to the product website.
While the product safety information page is among the top five pages visited what alarmed me was that time on the page was measured in seconds not minutes for most online visitors. Who could blame them when the safety information sounds like a medical journal?
For some reason, the FDA still requires fair balance on website home pages. It’s a huge waste of space, money, and time. When online health seekers come to a pharma product website they want to know “what’s in it for me?” and “how much the drug costs”. Sure, they will go to the product safety information page but it’s too hard for them to comprehend.
Fair balance needs to be scraped and the FDA needs to start by asking “what are people looking for when they come to a drug company product website?
I see that online health seekers are listening to other patients to learn about drug side effects. If enough people say that they had a headache, it gives them something to think about when deciding on a treatment. Based on what I have seen, perhaps it would be best if the fair balance indicated the percentage of people who, in clinical studies, had a particular side effect.
Let’s think about this for a minute. If your product’s side effect is lowered immune system response to infections, perhaps online health seekers would like to know what percentage of patients taking your product had this side effect?
What about TV and online ads?
Anyone who thinks that someone will make a treatment decision based on a TV or online ad needs a drug test. It doesn’t happen, and the FDA should know this by now. It’s a waste of time and money.
Rather than put fair balance or safety information on web home pages, a link to safety infromation pages should be available on EVERY page so people can easily go to safety information.
The other information that’s missing is how many people are in or participated in clinical trials. People want to know how many people have used your drug over time in and out of clinical trials.
The FDA is floundering with trust issues. A revamp of fair balance based on the real world is desperately needed.