There is a growing concern about using certain promotional techniques for drugs and devices that have been "imported" from other industries (e.g., packaged goods). The FDA, for example, cited the use of coupons, free samples, free trials, and money-back guarantees in pharmaceutical advertising as examples of techniques it wishes to examine in its November public meeting (see "FDA May Follow PhRMA's Lead on DTC").
I think that it is fair to say that many pharmaceutical marketers have come over from the packaged goods and other industries and have brought with them and applied techniques they have commonly used for consumer products. This was in response to the criticism often leveled at the drug industry that it did not understand how to market to "consumers."
We can get into a whole discussion of whether or not patients are or should be considered consumers. But I'd rather focus on two advertising techniques that require industry self-imposed ethical guidelines or, failing that, regulatory guidelines from the FDA: celebrity endorsements and buzz marketing. Neither of these techniques is addressed in PhRMA's "Guiding Principles" for DTC advertising.
The FDA also is interested in the use of celebrity endorsements:
"Such approaches plainly do not reflect a data-oriented approach to promotion and may not be recognized by consumers as anecdotes," the agency wrote. ÂFDA is interested in whether and how techniques mislead consumers about the risk-benefit tradeoffs of prescription or restricted medical products." (See FDA's statement in the Federal Register.)Dorothy Hamil may forever be associated with the Vioxx debacle. She is the poster child for the anti-celebrity endorsement proponents. I, however, prefer Rafael Palmeiro, aka "Viagra Man." On the one hand, we're supposed to believe him when he says he takes Viagra, while on the other hand, we now know he lied about taking steroids!
That's the problem with celebrity endorsers: YOU CAN'T TRUST THEM! Or, you can't control them. By linking them to your product, you assume a risk.
I have been surveying pharmaceutical marketers on this and other pharma marketing techniques that may be examinedd by the FDA (see "FDA Regulation of DTC Survey"). Almost two-thirds of respondents agreed with the statement: "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?"
Here are a few specific comments I received so far:
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.Buzz Marketing
Celebrity endorsements or actors playing doctors is a form of fake advertising that should be banned.
You first have to have the trust and confidence of the patient in the drug. A celebrity cannot create trust, even if a consumer/patient may like them.
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.)
Buzz or "Word-of-Mouth" marketing is popping up at pharmaceutical industry conferences. This type of marketing employees consumer peers (and celebrities, I guess) to spread kind words about products. Buzz may be most effectively employed via the Internet where, for example, a patient on a disease discussion board might say nice things about a drug that treats the condition.
I don't know how prevalent buzz marketing is in the pharmaceutical industry, but I have joked about it and noted that buzz marketing is currently unregulated (see "Buzz is NOT regulated by FDA"). In fact, some buzz marketing may be illegal (see "Is Buzz Marketing Illegal").
What I do know is that pharmaceutical companies are using services that track how their products are mentioned on the Internet -- i.e., whether it's a positive mention or a negative one. The logical next step is to try and influence the buzz.
According to AdAge Online article cited above: "As marketers more frequently look to recruit consumers brand agents to spread goodwill for brands, industry attorneys view buzz marketing as a likely area of regulatory involvement, especially around the issue of compensating people to participate in buzz programs when they fail to disclose their connections to marketers and agencies."
I am sure that Tom Cruise did not receive any pharmaceutical money when he "dissed" antidepressants, but I am not sure that a celebrity on the Ophra Winfrey show who mentions a drug product did NOT get paid to do it. Nor would I know if that patient on the online discussion board got paid. The only way I would know is if the endorser disclosed that he or she was compensated by the manufacturer.
And that's the Catch-22 of buzz marketing: if you disclose, you dispose (of the credibility).
RULE OF THUMB: All DTC advertising -- like all drugs -- has some risk. Marketers should do a risk-benefit analysis before using celebrity endorsers or buzz marketing.