DTC Regulation: Trick or Treat?

At a post-Halloween public hearing this week, the FDA will be soliciting public commentary about several direct-to-consumer (DTC) advertising techniques employed by pharmaceutical marketers. This process is scary to some pharma marketers who fear a new round of DTC regulations from FDA. This trick, however, may have been forestalled by PhRMA's treat: its Guiding Principles for DTC, which were revealed in August (see FDA May Follow PhRMA's Lead on DTC).

I will be attending this meeting and will report here on what, if anything, I learn (see "FDA May Follow PhRMA's Lead on DTC" for more information about this meeting).

Survey
Meanwhile, for about a month now, Pharma Marketing News has been hosting a survey of subscribers and other pharma marketing professionals to get their opinions on the issues the FDA will be discussing at the upcoming public hearing.

Just a few of the questions being asked in this ongoing survey:

• How good a job are pharma marketers currently doing to educate consumers about diseases in DTC advertisements in the following media?
• What is the potential role of reminder ads in all types of consumer promotion, such as broadcast, print, and the Internet?
• How good a job are pharma marketers currently doing to educate consumers about communicating risks in DTC advertisements?
• In your opinion, does the use of celebrity endorsements or actors playing doctors in DTC ads mislead consumers about the risk-benefit tradeoffs of prescription drugs?

I summarize below some of the preliminary results from this survey. This is NOT a scientific survey and the results should not be generalized to estimate the views of all pharma marketers. (Click here if you wish to participate in this survey.)

Is DTC Educational?
As you may know, PhRMA (the industry's trade association) and professional pharmaceutical marketers in general believe that DTC advertising is educational (e.g., Pfizer CEO McKinnell wants to call it "Direct to Consumer Education" rather than advertising; see "McKinnell's Mea Non Culpa").

No doubt DTC ads educate consumers about Rx products, but how well do they educate consumers about the conditions that these products treat? This is where I have focused much of my criticism in the past (see, for example, "Is DTC Educational or Motivational?"), so you know what I think. But, you might be surprised by the opinions of marketing professionals.

Much of the focus on DTC really concerns ads run on TV. But other media are also used by the pharmaceutical industry to promote their products to consumers, including radio, print and the Internet. I was curious how the educational merit of DTC depended on the medium and this was the first question asked in the survey.

Internet Is Best Medium for Education
A large majority of respondents (66%) believed that pharma marketers did an excellent or good job via the Internet educating consumers about diseases treated by the products. In contrast, only 22% felt the same way about TV commercials.

One example of bad educational TV DTC ads is the promotion of ED Drugs (Viagra, Cialis, Levitra). The TV ads say absolutely nothing about erectile dysfunction, who may be "at risk" for developing it, what causes it, etc. On the Internet, however, all this is explained very nicely (at least on the drug.com sites) -- complete with pictures and "circles and arrows .... on the back of each one explaining what each one was" (pleas excuse obscure reference to Arlo Guthrie).

It's a shame, however, that drug companies spend such a miniscule portion (ranges from 1% to 10%) of their consumer marketing budget on the Internet. Some pundits believe that restrictions on TV DTC advertising will lead to much more use of the Internet. Maybe, but if history is any indication of the future (as your stock broker would have you believe), I would not hold my breath.

[NOTE: TV ads can't cover everything in 30 or 60 seconds and some ads do a better job than others explaining the medical condition, especially if the condition is not well recognized. ED ads could at least have a voice over directing viewers to the Web sites where they can learn more about ED.]

Back to the survey (which I will look at in more depth in an upcoming article in Pharma Marketing News).

Branded vs. Non-Branded Ads
The survey asked people about non-branded ads such as disease-awareness ads and compliance ads -- should the pharma industry as a whole adopt Pfizer's policy (beginning in 2006) to "invest a meaningful amount -- on par with what it spends on a branded advertisement campaign" -- in non-branded ads?

Fifty-six percent (56%) of respondents said "Yes", 33% said "No" and the rest had no opinion.

There is at least one fly in this ointment that was pointed out by a respondent:

"Does this mean non-product branded or non-corporate branded, or both? If both, that's charity, which may or may not be acceptable to shareholders. Otherwise, one might argue that the spend is for corporate "goodwill," which may be a good idea in good times, but may not be sustainable in the face of business downturns. Making a fixed commitment to spend equal amounts of money to promote product branded ads and "non-branded ads" might be good politics in the current environment but is not, in my opinion, very good public health or corporate policy."

Indeed, Pfizer does NOT pledge to spend all that extra money and resources solely on "disease-awareness ads," nor does it pledge to do so forever. What Pfizer does say is:

"In 2006, Pfizer will invest a meaningful amount—on par with what it spends on a branded advertisement campaign—to:

• Create more disease awareness with advertisements that do not mention a product, such as the recent 'Why Live With Depression' campaign that featured actress Lorraine Bracco.
• Address other important public health issues such as health literacy, compliance or improving the patient/physician relationship through additional non-product advertising.
• Continue our dedicated advertising campaign and efforts to promote 'Pfizer Helpful Answers.' "

So it seems there's going to be quite a bit of corporate goodwill ads thrown in the mix.

Celebrities in Ads and in Buzz-Generating Venues
It's interesting that Pfizer mentions the use of celebrities in its ads -- this practice will also be examined by the FDA at the public meeting (see "Celebrities & Buzz Revisited").

The Pharma Marketing News survey asked the following question regarding use of celebrities:

"In your opinion, does the use of celebrity endorsements or actors playing doctors in DTC ads mislead consumers about the risk-benefit tradeoffs of prescription drugs?"

Fifty percent (50%) of respondents said "Yes" and 33% said "No." Some comments from respondents:

"This is a grey area--Dorothy Hamil for Vioxx is a classic example of misuse of celebrity endorsements, but I can envision applications which are not misleading."

"Celebrity endorsements or actors playing doctors is a form of fake advertising that should be banned."

"If all key strategic content, disease awareness, disease prevention and product benefits and risk, are handled properly, then the use of celebrity endorsements can make a good ad more effective."

"Here, the risk-benefit trade off should be considered: How much risk the consumer takes by consuming the advertised drugs (based on the celebrity endorsement)and the benefit the company gets on account of boost in sales this is very crucial in that consuming a particular brand of soap because it is endorsed by your favourite star is definitely less risky than doing the same with a prescription drug (without considering indications, side effects etc.)"

"Mass marketers, social marketers and the government itself, all use celebrities to attract attention to their messages and causes. There is nothing "misleading" about that. Communication of information concerning risk-benefit tradeoffs of prescription drugs is a separate issue. If the message is an appropriate one (the key issue), the use of celebrities only enhances thlikelihoodod that it will be heard through the clutter."

Transparency is the Real Issue in Celebrity Endorsement
For me, the real issue is: Should celebrities who are paid to promote a product or talk about a disease mention this fact when they are interviewed on talk shows and in other situations that are assumed to be non-commercial in nature? In these situations, consumers are expecting honest, unsolicited opinions, not opinions paid for by pharma companies. It doesn't really matter if the celebrity truly believes what he or she says, potential conflicts of interest should be revealed.

That's it for now. Hope to see you in DC!