Adapted from my "Futurist" column from the Jan. 19 issue of CQ Weekly.Pharmaceutical advertising can cause drowsiness, irritability, mild confusion and occasional hypochondria. People experiencing prolonged humming of jingles derived from old Elvis Presley songs should consult a doctor. After all, getting you to contact your doctor is one reason drugmakers spend billions on all those ads, anyway.
Like most marketers, pharmaceutical companies are slowly shifting their advertising focus to the Internet. Changing media habits are a contributing factor: Web activity now rivals radio and print, and by some measures is gaining on television's reach, even when excluding at-work Internet use. Online marketing offers targeted audiences at a low cost, too.
But pharma's growing interest in online also relates to the distinctly stringent way direct-to-consumer marketing messages for prescription drugs are regulated, especially on U.S. television. With Congress expected to consider even more restrictions, creative Internet advertising looks more appealing than ever -- and poses challenges for the Food and Drug Administration, which already struggles with its responsibility to monitor the marketing of prescription medicines in all media.
This shifting media landscape helps explain how Debbie Phelps -- mother of Olympic swimmer Michael Phelps -- ended up on Facebook last year, working as a paid spokeswoman for a new online group for parents of children with attention deficit hyperactivity disorder. The
"ADHD Moms" page offers space to share stories, access articles and vote in online polls. The page shows up prominently when users search for information on the disorder on the hugely popular social networking site, and more than 7,000 "mombassadors" have declared themselves "fans" on their personal profiles.
ADHD Moms' sponsor is
McNeil Pediatrics, a division of Ortho-McNeil-Janssen Pharmaceuticals Inc. Its role and logo are highlighted near the top of the page, but a user would need to click through to the company's Web site to learn that it's "a leader in the treatment of Attention Deficit Hyperactivity Disorder" -- a reference to
Concerta, a commonly prescribed daily treatment for ADHD.
Parent company Johnson & Johnson has been in the vanguard of this kind of indirect, community-oriented online marketing for prescription medications -- setting up blogs, Facebook pages and YouTube channels to help extend its brands. Some drugmaker marketers see campaigns like those as the industry's future.
"The genie is out of the bottle," said Peter Justason, a global marketing director for Johnson & Johnson, in a recent
TNS Media Intelligence report on using "social media" for branding. "Now it doesn't cost anything for a million people to get online and talk to each other. People are trusting people like themselves more and more, as opposed to some sort of third-party authoritative figure."
FDA's regulations for digital communications are the same as those for direct-to-consumer pharmaceutical messages in other media, including rules against promoting a product's possible off-label uses and requirements that drug companies clearly disclose potential side effects and adverse reactions. If anything, the Web may provide better opportunities for that kind of disclosure than the tiny type in magazines and the fast-talking voice-overs on TV. "It's hard when you only have a 30-second spot," says John Mangano of comScore Inc., a market research firm that
advises pharmaceutical clients on online issues.
Nonetheless, drug companies have been slower than other industries to explore social media's potential. A key concern: "user generated content," such as the stories and comments posted on ADHD Moms. Some in the industry fear that user comments will dramatically increase reports of possible adverse reactions, which the companies are then legally required to document. (See Brandweek:
"Why Pharma Fears Social Networking", Oct. 20, 2008)
Such worries have kept many drugmakers from doing anything more online than buying some ads and creating static, carefully vetted Web pages. But that could soon change. In a series of videos posted on his site,
EyeOnFDA blogger Mark Senak notes that Congress is likely to consider imposing a moratorium on TV ads for newly approved drugs and restrictions on direct outreach to doctors and medical groups -- moves he predicts would accelerate the pharmaceutical industry's online shift. "Traditional concerns" about Internet marketing "actually crumble in the face of the fact that coming reforms are really going to demand new approaches," says Senak, who's an executive at Fleishman-Hillard. (Here's Senak's video series:
"Changing Policy Landscape," Part 1,
Part 2,
Part 3)
Could increased online marketing of prescription drugs attract the same level of legislative and regulatory scrutiny that broadcast advertising has? Sure, but Senak thinks that's a long way off. And the FDA is far from ready to take on such a challenge. The
Government Accountability Office has found that FDA's small staff for monitoring drug marketing has labored with the growing volume of industry submissions over the past decade, including 4,600 offline pieces and more than 6,100 online pieces in 2005 alone.
One way the agency might accelerate enforcement efforts is using social media. The FDA is beginning to develop
a new "Web portal" to make it easier to report adverse drug reactions. A similar approach might allow consumers to report potentially illegal advertising, too. For now, however, the agency Web site provides only an elusive link -- with a phone number and a mailing address. (See the
third-to-last answer on this Q&A from FDA's consumer guide on drug ads.) Very old media.