Since PhRMA's Guiding Principles for Direct to Consumer Advertising became effective in January, 2006, there have been several sightings of reminder ads on TV. The latest such sightings involve Lunesta (see "Wake Up PhRMA! or Tilting at Windmills").
"Guiding Principle" #10 for Direct-to-Consumer Advertising states:
"DTC television advertising that identifies a product by name should clearly state the health conditions for which the medicine is approved and the major risks associated with the medicine being advertised."But this and other PhRMA principles do NOT apply to other advertising channels such as the Internet and, it now seems, outdoor billboards.
An anonymous Pharma Marketing Blog volunteer "DTC Stalker" found a misbehaving Levitra outdoor ad over the entrance to one of the most heavily trafficked sites in the world: Penn Station/Madison Square Garden in New York City. Our operative whipped out his camera-equipped cell phone and sent in the following photo to document the sighting:
Shift in Pharma Ad Budgets, Not Type of Ad
Many pharma advertising gurus have suggested that PhRMA's DTC guidelines would mean less spending by pharma on TV and the transfer of money from that budget to other channels -- especially the Internet and direct mail. Many of us thought that would be good because these channels offer more targeted, information-rich messages.
Not too many experts, however, suggested a windfall for outdoor advertising, which is even less targeted and information-rich than TV! More importantly, however, we did not think pharma advertisers would use their TV reminder ad budgets to continue saturating the market with these ads in other venues!
Where's the Education?
While Penn Station may not get as many visitors per day as the Yahoo! home page, this ad is equivalent to a banner ad on the Internet, EXCEPT there is no clickthrough to bring you to the "educational" information PhRMA says that DTC can provide:
"We know that DTC communications can be a powerful tool for reaching and educating millions of people, and we are committed to ensuring that our DTC communications provide accurate, accessible and useful health information to patients and consumers. DTC advertising of such important and powerful products as prescription drugs should be responsibly designed to achieve these goals and to encourage the appropriate use of these products." -- PhRMA DTC Guiding Principles [my emphasis]The Levitra ad certainly is not educational, does not provide useful health information, and is not responsibly designed to achieve any other purpose than brand recognition. As advertising, it is no better and no worse than an ad for Coca-Cola or Pepsi!
Bayer, one of the marketers of Levitra, is a signatory to PhRMA's Guiding Principles and, like all pharma companies who signed on, made a big deal of it and had their highest ranking executives make "sound-bite" commitments, which in light of these reminder ad sightings that violate the letter or spirit of the guidelines, ring hollow indeed. Arthur Higgins, Chairman of Bayer HealthCare's Executive Committee and member of the PhRMA Board of Directors, said the following:
"These guidelines will help DTC better promote disease state awareness, provide consumers broad access to important and accurate health information -- including the benefits and risks of medicines -- and encourage important discussions between physicians and their patients."The Levitra ad outside of Penn Station does none of that!
Mister Higgins, tear down this ad!