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August 29, 2017 Aaron Uydess0

The scope of what we call marketing seems to be growing every day. Within the professional lives of many in the business of pharmaceutical marketing, a campaign of one-size-fits-all magazine ads alone was considered sufficient to launch and sustain a multi-million-dollar brand. Then came television, then the internet, then mobile devices, and on and on – and with each, the expectations of our audiences have grown. Today customers expect an experience from brands, one that caters to their individual needs through a variety of media, especially digital and interactive media. And for all the progress in the digital space, pharma as an industry has not done a particularly good job of providing these coordinated and customized experiences. How to improve? Read on.

Mobile-friendly just isn’t good enough.

Adapting your desktop website to make it “mobile-friendly” is starting to look a bit backwards, given that more than half of web traffic is now coming from mobile devices. If we really want to engage our audiences where they want to be engaged, we need to be thinking mobile first. Every patient interaction that we seek in the digital space – ads, websites, interactive content, email, all of it – should be created with the mobile experience at top of mind. Old-fashioned responsive design works okay for vanilla text content, but any communication tool with any degree of complexity in it ought to be built for mobile, not just able to adapt to it. Agencies and marketers need to adapt to capture attention in the first 35 characters of email subject lines. They even need to think about thumb fatigue when designing pages that may be too long.

Mobile-savvy patients expect quick hits.

People don’t use mobile devices for the same reasons they use desktops. They don’t go to their smartphones to do in-depth research; they go there to find information fast. So marketers need to be tailoring their mobile experiences that way. A good mobile site should offer access to information, services and tools quickly – services and tools like health trackers, copay support apps, specialist or pharmacy locators, non-intimidating patient education portals, touch-here-and-ring-the-patient-support-center-right-now. Great masses of text or dozens of links on a page are not your friend in the mobile environment. We see a day in the near future where patients can even “FaceTime” with their doctor or nurse for live but remote care. Telemedicine, powered by mobile and a desire to reduce healthcare costs, is about to boom!

Plain old targeting isn’t enough any more either.

Data is everywhere and those that capitalize on it will win. So we need to target more deeply – to hypertarget – and think in terms of the cultural prisms through which our audiences will view our communications. To do this we must move beyond traditional segmentation and actually build whole experiences to match each segment. For example, if your brand might have an opportunity in the Hispanic population, you should be developing your communications for that population from the ground up, not just as an offshoot of the “standard” materials. In the old days marketers used to write everything in English and translate as necessary – but today’s audiences, whatever their ethnicity, are expecting more than that. So cultural adaptation versus plain translation is the key to connecting with multicultural audiences. They are expecting communications and images and services that are attuned to their cultural background, and may be actively turned off by those that aren’t.

Leverage landing pages – and please, let’s optimize them.

A handful of pharma brands are beginning to catch on to the vanity URL and landing page concept – creating landing pages focused on narrower topics within and then strategically salting ads with them, with the hope of creating a deeper connection. For example, one might embed into a TV ad that focuses on copay information, so that the patient ends up encountering multiple reinforcing messages. The trouble is that, as frequently happens in pharma, too many brands are investing in vanity URLs, tossing them out into the marketplace, but never really following up to optimize their use. With just a little added push – the push of A/B testing multiple URLs in the same ad or multiple ads with the same URL – brands could find out which combinations generate the most click-throughs, the most interest – and the best experience for the patient. The idea is to make every dollar work as efficiently as possible. If patient experiences are to be a matter of priority for your brand, you’d best be paying attention to the outcomes of those experiences and optimizing accordingly.

Mind your language, and how much of it there is.

We love our content in pharma. Maybe it’s how invested we are in our brands, or maybe it’s the regulatory requirements and complex review process, but we as an industry find it difficult to resist loading up our patient communications with everything at once. Yes, some of that cannot be avoided due to the need for important safety information and fair balance. But even on top of those guidelines we tend to be content-verbose, trying to squeeze everything into one experience or capture everything possible in a single registration form. It takes a true digital marketer to have the confidence to keep it short, sweet, and sticky, creating an experience and journey over time that delivers the content and value to the patient in digestible pieces.

So we need to narrow the focus of our messaging. Let our customer choose what he or she is seeking and provide it, and it alone, with a pathway to more as needed. Lose the long pages with multiple messages. Offer one call to action rather than four. Keep everything simple, scannable, short, and sweet.

Integrate, integrate, integrate.

Pharma companies love to create monuments to their brands. They can’t just offer a diet tool; it has to be the company’s branded diet tool. But customers don’t think that way. Customers want tools that are applicable across the whole spectrum of their lives, and they don’t much care what brand is attached. For example, many patients with diabetes have other health issues, too, like hypertension. In our present brand monument environment, that might mean one health tracker from the diabetes company, another from the cardio company, and maybe even another from the weight loss company, all beautifully lacquered up with each brand’s name. Or, the patient could use Apple’s Health app, which can take inputs from virtually anywhere and cover all of those bases, creating a simpler experience. Which do you think the typical patient will choose?

So we need to start thinking more holistically. If we really want to improve the patient experience, we have to start building tools and services that can be tied together with other tools and services, even third-party ones, rather than just monuments that are unique and proprietary to our own brands and companies. And yes, some companies are doing this already – Novo Nordisk with Glooko, Sanofi with Google, Novartis with Verily. But we need to see more of it. If a truly integrated and productive patient experience is going to be a matter of priority for pharma brands, we are going to have to start partnering across industries and converging when possible to provide patients the ideal seamless experience.

August 29, 2017 Denise Erkkila0

Today’s healthcare environment – with access to therapy and pricing top of mind, new “right to try” laws, possible legislative changes, and big shifts in the ways that consumers get health information – requires more innovative and thoughtful approaches on how to communicate than ever before. For many pharmaceutical companies, advocacy is a highly promising and rewarding way to connect with patients, families, and communities. Now, some of those efforts are coming under scrutiny.

Advocacy organizations exist to help the people and communities they serve, and can have some impressive reach. One great example is the fact that breast cancer mortality is down 38%, influenced by efforts of Susan G. Komen® to leverage science and education, and directly help patients. And there are numerous reasons that industry stakeholders engage with advocacy groups. Many pharmaceutical companies collaborate with advocacy organizations on non-promotional and unbranded activities to support the community in capacity building, education, and to build advocacy skills. Some have more direct brand objectives in mind, and support advocacy organizations with the goal of getting endorsements from the advocacy organization or from patient ambassadors. Some work with advocacy organizations so that they will recommend specific products to their constituents or to speak with legislators on behalf of companies or products.

Transparency is key to building trust

Trust is essential to building fruitful relationships between the community, advocacy groups, and industry. But lack of transparency can undermine these relationships and may have a negative impact on how the community perceives advocacy organizations and by association pharmaceutical companies. Because trust between them and the communities they serve is key, some advocacy groups have chosen not to accept pharmaceutical funding, so they can say that they are completely outside the influence of industry. The reality, however, is that it is extremely difficult for many advocacy organizations to provide the services and develop the reach and consistency they would like based only on their own public / private support and community fundraising. For this reason advocacy organizations are often open to mutually-beneficial partnerships with industry that ultimately help the patient communities they serve.

But the current level of transparency around funding of advocacy groups has recently been questioned. The New England Journal of Medicine and JAMA Internal Medicine published articles that assessed whether advocacy organizations might have significant conflicts of interest because they accept support from pharmaceutical companies. What the investigators found raises questions about the need for added transparency. According to the New England Journal of Medicine article, 80% of large organizations (annual revenue at least $7.5 million) were found to receive industry support. However fewer than 20% reported specifically how much they received from industry sponsors. More than one-third had an industry executive on their board, and another quarter did not state their board members’ occupations. Only about a quarter published conflict of interest policies, none of which specifically addressed industry influence.

Findings published in JAMA Internal Medicine revealed that two-thirds of smaller organizations (median annual revenue $299,140; interquartile range $70,000 to $1.2 million) were funded by industry and more than 10% received more than 50% of their funding from industry. More than 80% from these smaller groups felt that advocacy organizations should be cognizant of the potential for conflicts of interest, but only about half were highly confident in their organizations’ conflict of interest policies. More than seven percent were consciously aware of pressure to align with corporate interests of donors. The findings illustrate how the majority of large and smaller advocacy organizations receive funding from pharmaceutical companies, but do not have applicable conflict of interest policies to preserve transparency – potentially raising questions about credibility and undermining trust.

Advocacy organizations are not the only ones coming under scrutiny. Since 2013, the federal government has issued subpoenas to a number of pharmaceutical companies to analyze their ties to patient assistance charities. The investigations continue, and now involve many top pharmaceutical stakeholders. These inquiries are similar to those concerning financial ties between industry and physicians and their institutions, and potential conflicts of interest that could influence physicians’ clinical decisions. Financial ties must be disclosed to avoid a potential conflict of interest, or even the appearance of a conflict of interest, so that patients’ welfare remains the primary interest.

Advocacy is stronger with transparency

Should the pharmaceutical companies stop supporting advocacy organizations? Absolutely not. However, all parties should be transparent about their relationships and financial support. Recently, Stat News reported that a pharmaceutical company was found to be a secret funder of a patient advocacy organization that was working to secure more government funding and insurance coverage for treatment. Because this charitable donation was initially concealed, “outing” the company as a financial supporter became the news story. This shifted the focus from the potential positive impact of support for this advocacy group, and possibly diminished the advocacy group’s important role and ability to address a critical community need. Transparency is an effective way to help advocacy groups avoid the pitfalls of implied or actual bias concerning their work, removing a potential barrier for positive impact on the community.

Just as pharmaceutical companies have to publicly disclose payments to physicians, and many physicians are required to disclose any potential conflicts of interest based on industry relationships, it is reasonable to ask advocacy organizations to disclose their industry sponsors and the financial support they receive. This could be similar to a Sunshine Act for advocacy – only hopefully with less complexity! The goal is for all stakeholders to feel confident that everyone is transparent and playing on a level field and lets communities feel positive about the organizations representing them.

August 25, 2017 Bob Ehrlich0

I see doctors more than I used to due to my advancing age. That gives me a chance to see more point of care marketing as I go to my many specialists for a variety of ailments. I often wonder how much patients are receptive to being educated while in the waiting room or in the exam area. Most doctors’ offices are a media smorgasbord of general interest magazines, health pamphlets, TV’s playing news or promotion for products physicians sell.

Bob Ehrlich
“Clutter is a significant barrier for POC media companies…”
-Bob Ehrlich

Clutter is a significant barrier for POC media companies trying to prove to drug makers an acceptable ROI for their products and services. Patients also have their own entertainment system with their mobile devices and the growth of in office Wi-Fi makes them a viable entertainment option in waiting rooms. The challenge for POC companies providing information on disease or branded products is how to get their share of attention in that valuable 10-20 minute waiting period.

The days of just providing and expecting positive results from general disease information through a video, wallboard, or publication could be numbered. More needs to be done to grab attention given the numerous media alternatives available. That means POC companies are going to have to invest more in researching how patients actually behave in the waiting room. That is, what draws them to put down their mobile device and watch a POC video, interact with a tablet, or read a wallboard or custom health magazine. As patient choices expand, drug companies are going to expect some sophisticated analysis of patient in office viewing habits.

POC generally has reported higher ROI than mass media. The POC media companies are going to have to work hard to keep that advantage. It is clear that every drug company is looking to take full advantage of the marketing opportunity at POC. That physician office is the pivotal point in generating an Rx. Every drug maker wants to maximize that pre-exam time frame with disease and/or branded information.

We are seeing consolidation of POC companies through acquisitions. Having fewer and larger players with deeper pockets makes it more likely we will see new patient behavioral research. I would expect, as a drug marketer, to have the POC media companies do lots of testing on how to generate patient attention. Their technologies now allow for streaming in a highly targeted manner. That could mean different messaging down to a local physician level taking into account patient demographics. Drug makers are going to expect POC media companies to increasingly present innovative ways to get patients to pay attention in an increasingly cluttered waiting room.

I was in my ophthalmologist’s office this week and was entertained by a POC module from Outcome Health, formerly ContextMedia:Health. They had a reporter on the street interviewing people with trivia questions on eye issues such as incidence of eyeglass use and contacts. I noted everyone in the waiting room was watching as it was a different and attention grabbing way to educate patients. We all had our mobile devices in our hands but took a break to see the answers to the trivia.

What I have noticed through my many physician visits is that there is still massive opportunity to bring media innovation to the waiting and exam rooms. There are a number of great companies in this space and continuing consolidation will bring more consistency to what patients see. Drug makers will welcome being able to expand POC use with larger media companies controlling more offices. That consolidation may make it harder, however, for start-ups to compete but hopefully we can still have opportunities for the small entrepreneurs. After all, the current POC giants all started relatively recently as small businesses with a new way to educate patients.

August 18, 2017 Bob Ehrlich0

In what may be a major step towards reducing the litany of risks presented in DTC television ads, the FDA released their new study that shows that less risks presented is better for consumer comprehension and retention. While saying further study is needed, FDA cleared the way for perhaps eventually changing its guidance on the number of required risks presented. This study, originally posted for public comment in January 2015, saw the results published August 2017 in an online research journal.

Bob Ehrlich
“FDA would be wise to issue a new reduce the number of risks…”
-Bob Ehrlich

FDA studied alternate risk disclosure in three categories for this study. Insomnia, depression, and high cholesterol were tested with reduced risk disclosure. While full details were not yet published the conclusion is that consumers remembered more when less was presented. We all know the current approach is not optimal because consumers get bombarded with so many risks and side effects, both in voice overs and on screen supers.

So here we are 20 years into DTC on television and we get the widely expected answer from the FDA study. While this study is better late than never the FDA says further research is needed. FDA would be wise to issue a new guidance soon giving drug makers the chance to reduce the number of risks and side effects. Consumers could immediately benefit by retaining more of the important information. I am even supportive of keeping the ads just as long with fewer risks discussed. Supers could kept on the screen longer and a slower voice speed could be used for discussing risks.

FDA has lots on its DTC research agenda, but this area of risk presentation is of major importance. Action should be a priority because consumers are overwhelmed with risk information under current requirements. The goal of all involved in DTC should be helping consumers get comprehensible risk information. The shortened risk requirement would help in achieving that goal.

August 17, 2017 Linda Ruschau0
Sponsored Content

Every 42 seconds, someone in the US has a heart attack. Each minute, someone dies from a heart disease-related event.1

Even though heart disease remains the leading cause of death in the US, many adults are uninformed of the causes, symptoms and proper treatment of heart-related conditions. In fact, according to PatientPoint research, over half of patients who are treated for heart health said their issues were unexpected. Further studies have found 70% of adults are not familiar with symptoms associated with heart disease.2

As these statistics reveal, the need for education and support materials for patients at the point of care is paramount – and critical to pharma companies’ success. Because if heart health isn’t top of mind for most adults, it’s likely your treatment isn’t, either. And with nearly half (47%) of cardiologists now restricted, gaining awareness among physicians is also a growing challenge.3

To ensure the right message is delivered to these heart “unhealthy” patients at the right time, PatientPoint conducts in-depth research in the space. Here’s a snapshot of patients who visited cardiologist offices installed with the PatientPoint Communicate – Cardiology Waiting Room Digital Screens Program:

  • Average age: 60 years
  • Gender: 60% female
  • Race: 79% white / Caucasian
  • Employment status: 59% retired
  • 42% are accompanied by another adult
  • 59% want to lose weight
  • Top conditions identified to be at risk for or diagnosed with: high blood pressure / hypertension (72%), high cholesterol (68%), arthritis (55%), heart disease (53%), heart attack or cardiac event (48%)

This information enables us to develop content specifically tailored to these conditions, gaining unprecedented positioning as a trusted consultant to our partners – clients, physicians and patients – to ensure their message makes the most impact at each important moment.

Let’s look at each of these points a little more closely:

  • Waiting room: Patients say the waiting room is often the most stressful part of their visit to the doctor. Reinforcing your brand message alongside easy-to-understand digital information regarding heart health, healthy living tips and personalized messages from the practice will put your brand top of mind right before patients visit with the doctor. Heart patients don’t want to hear about arthritis content. We speak the patient language.
  • Exam room: Once in the exam room, patients crave in-depth education. Interactive touchscreens bring health information to life, whether it’s through a personalized quiz, short article or a brand testimonial video. Once the doctor arrives, he’s likely to use the touchscreen to show the patient exactly what’s happening in her heart via full-color, 3D anatomical models. It’s here where your brand can provide the support and savings information to help guide discussions and, ultimately, decision-making.
  • After the visit: Because the risk factors for heart disease and stroke are directly related to lifestyle choices, continual engagement between provider, pharma company and patient is important to ensure treatment success. We know those age 45-64 (the common age range for the onset of many cardiovascular conditions) still see print as a valuable information resource,4 and including your message in brochures patients can take home and reference later will help reinforce your brand as part of the solution to living a longer, healthier life.

The scale of the cardiovascular market is driving greater demands of quality outcomes data. Providing the right education to patients and providers at the right moments will help pharma companies remove barriers to access and support long-term adherence.



  1. American Heart Association, 2015
  2. Cleveland Clinic survey, 2014
  3. ZS Associates, “AccessMonitor,” 2015 Executive Summary
  4. 2015 Two Sides North America

August 14, 2017 Richard Deede0

If you haven’t been living under a rock (or aren’t my parents), you are probably aware of the rise in popularity of voice search and voice enabled devices. Thanks to technology like Google Assistant, iOS Siri, and Amazon Echo, voice search is exploding in terms of both adoption and technology integration.

A comScore study in 2016 noted that 40% of adults now use voice search at least once per day and 60% of those people started using it in the last year. A recent report estimates that more than 24 million Amazon Echo and Google Home devices will be sold in 2017. As the technology behind these devices improves, people are turning to them at an increasing rate to obtain information, seek answers to their questions and incorporate them as a part of their daily routine. Because people can typically speak up to 150 words per minute versus being able to type 40 words per minute, and using voice search is seen as quicker than typing or using an app, voice search continues to grow in usage.

The manner in which people are using voice search, beyond just music playback, seems to focus on location based queries and answering basic questions. These uses line up well with the core functionality of voice search and are natural first steps for many people who are getting familiar with the voice search format.

However, there is much more potential in how voice search can be utilized to engage with searchers beyond what we’re currently seeing – this is especially true in the health information space.

Using voice search for health information
Currently, the number of voice search enabled health dedicated applications is very limited. One of the few available now is WebMD’s Amazon Alexa skill, which is essentially a custom voice search program geared towards health information. This new skill is aimed toward answering basic health questions and providing information in a quick and easy voice-enabled format.

Perhaps in the near future, voice applications could simply build on the commonly used question and answer format to help patients at the earliest stages of their health journey to identify potential health conditions and provide questions for them to ask their doctor.
However, while making use of the straightforward question and answer format is a good foundation, there is a plethora of untapped potential for the health information vertical to go even further and create truly interactive, immersive voice search experiences.

For instance, one of the real values of voice-based personal assistant devices is the way they have started to weave themselves into the daily routine of users. This adoption could be useful for people who manage their health conditions on a daily basis. People who live with diabetes, for example, have a variety of concerns they need to be mindful of which could potentially be tied in to the usage of voice based personal assistant devices. These uses could include:

  • Reminders can be given when it is time to eat, drink and check blood sugar levels
  • Using location-based weather forecasts, the assistant can give recommendations for exercises appropriate for that day and even skin care tips in order to keep skin hydrated
  • From a dietary perspective, when someone utilizes the “shopping list” feature of these devices, perhaps a diabetes app can recognize the ingredients and make suggestions for recipes to make using those ingredients that are diabetic friendly
  • Searches for recipes or restaurants can factor in diabetic restrictions when making recommendations, which will allow the voice search experience to be not only highly efficient but extremely personalized to that person’s location and health needs

As people continue to utilize voice search based devices, the amount of health information applications will continue to grow and open up new avenues to engage people with very individualized healthcare information experiences.

Taking healthcare conversations to voice search
It’s one thing to have a presence in voice search, it’s another to provide an application that people find truly helpful and improves the quality of their health journey. To create a voice search experience that is meaningful and useful, developers must provide people with trustworthy information as efficiently and accurately as possible in their moment of need. This is easier said than done, but the ability to offer such valuable and intimate service means there is the potential to become a part of each person’s daily routine.

Much of the potential value in voice search is in the organic experience it can create. Where healthcare is concerned, many people still feel that having a conversation about your health questions, such as you might have with your doctor, is a more natural and credible experience than Googling for information. Voice search and personal assistant devices have the capacity to create a conversational experience that can make people feel more comfortable and thus dive deeper into their health information search by engaging in a way that more closely mimics the interaction that might occur with their physician.

Healthcare brands and organizations who wish to make full use of voice search will have to be true to themselves and to their audience about the types of information they are seeking and how to answer those questions. For brands, this means potentially providing information that they might not normally be comfortable with discussing. Topics such as side effects and pricing are often avoided on brand websites despite searchers frequently looking for this type of information. In addition, we often see in our research that people commonly make comparison searches, essentially typing in “brand A vs brand B”. This is content that is typically not included in brand experiences. In order to feel comfortable engaging in voice search and adopting a vastly new method of searching for health information, people will need to feel as confident in the answers they are receiving as if they were coming from an unbiased source such as their own doctor.

As people embrace this new technology to seek out health related information, the healthcare world has a tremendous opportunity to make an impact. This starts with creating an experience that truly harnesses the value of voice search to empower the user to feel more in control of their own healthcare.

August 11, 2017 Bob Ehrlich0

The Vaccine makers have been very active using DTC to build awareness for some very serious diseases. Prevnar 13 from Pfizer has had a high spend campaign for its pneumonia vaccine. HPV has also been prominently promoted by Merck for Gardasil. Recently two new vaccines for meningitis B have hit the market and are going head to head. Pfizer’s Trumenba and GSK’s Bexsero both are going after the 10-25 year old market.

Bob Ehrlich
“We want drug makers to invest in disease prevention…”
-Bob Ehrlich

Meningitis B is a very serious bacterial disease involving inflammation of the spinal cord or brain. While rare it is deadly for about 10% of those afflicted and causes lifelong damage in many more who survive. About 10% of us have the bacteria in our saliva but overwhelmingly it does not cause meningitis. For about 600-1000 people annually the disease is devastating because it rapidly can cause death.

Trumenba became available in late 2015 and Bexsero a few months later. Trumenba began heavy DTC 3Q 2016 with Bexsero starting this June. Analysts estimate the meningitis market at about $2 billion. These are interesting case studies on DTC for a rare disease. The odds of getting meningitis are very low but the impact is so devastating that physicians, young adults and their parents are being advised by the CDC to consider these vaccines.

Drug makers have been criticized by some physicians and consumer groups for using fear based campaigns for vaccines. Why scare teens and parents? Is it right to use fear as a motivator in these DTC ads? Is it ethical to show the devastation of a disease that is rare to incentivize people to get vaccinated?

Yes, it is because untreated meningitis consequences are so bad. The vaccine is safe. It is moderate in price. The cost is usually covered by college health clinics but even self pay is reasonable at $350-600 for the series of injections. The ads for both vaccine brands are hard hitting and are directed at parents to show what could happen if the child got meningitis B. Of course, the drug makers want to increase the use of their vaccines and they know the market is wide open and incidence of use is currently low. They are trying to warn parents and yes to scare them. Sometimes we need to be scared into action. I see nothing wrong in these ads because the disease is a real, albeit low risk, and can be controlled with vaccines.

Would we have massive outbreaks of meningitis B without these vaccines? No, but saving lives and long term disability of teens and college aged kids is the issue. Society needs to balance the cost to payers for the vaccine versus the risks to the young adult population. Because the disease can spread so quickly any campus that gets a case will cause widespread fear across the community.

We want drug makers to invest in disease prevention for what we see now and may face in the future. If drug makers can develop markets through DTC they will be willing to devote more R&D investment to the vaccine segment. Vaccines and antibiotics are generally lower profit categories because use is short term. Let’s hope for success for current vaccines being advertised because one day we will need to be protected from a pandemic and must have a well developed vaccine infrastructure at big pharma.

August 7, 2017 Bob Ehrlich0

Many recent FDA warning letters involve what they say are distracting visuals during risk discussion. Last year Otezla and Toujeo were cited for that. A recent study using eye tracking reinforced their view that visual backgrounds on TV ads are potentially hurting comprehension of risks. Drug makers frequently mention some of the risks using supers on screen.

This FDA research completed in 2016 said that consumers do not absorb information well from those supers when there are distracting visuals. Of course, what is distracting is a subjective judgement from the FDA reviewer. My concern on citing drug makers for distracting visuals is the lack of evidence for that specific ad other than reviewer opinion. I understand FDA cannot quantitatively prove distraction for every TV ad they cite and must use informed judgement. I would hope, however, that FDA is consistent between reviewers and does not change over time. In a past column I said I did not think the Otezla or Toujeo ads were any different than many others not cited by reviewers.

Bob Ehrlich
“Consumers are bombarded with information that…may not be meaningful.”
-Bob Ehrlich

The problem with the fair balance requirement is that consumers are bombarded with information that may meet an FDA requirement but not be meaningful in terms of consumer understanding. FDA is studying the potential use of less warning information under the theory that less information may be better absorbed. My concern with this risk presentation is DTC is held to a different standard than every other advertising category for lawful products. Yes, drugs are different than most categories because they can cause harm. I recognize the need for telling consumers that drugs are potentially dangerous. The current litany of risk approach is, in my view, ineffective since a long list is not likely to be absorbed.

The issue is the role of warnings and risks in a television or print ad where time and space is limited. Drug ads are meant to inform consumers of an option for treatment and that is just the beginning of the pathway to prescription. The decision to prescribe any drug is an important one and side effects and risks are important for both physician and patient to understand. My view has been that only the most serious risks with the most harmful consequences should be disclosed in an ad and some quantitative odds should be mentioned. Any more than that is not particularly useful in the ad awareness stage. I clearly would want to know if anyone has died taking the advertised drug and the odds of it happening. I do not really need to hear a litany of possible non-fatal risks at the ad stage.

I hope the drug makers and FDA can work out a DTC risk and warning strategy that meets consumer needs. Consumers should be educated on benefits and risks but fair balance must be re-evaluated in the context of what consumers can meaningfully remember in 60 seconds or one page.