Pharma professional print ads and FDA compliance

I must say I was astonished to read the assessment (in the online journal PLos One) that well over half of pharma print ads to professionals are non-compliants with FDA guidelines.

Working for an agency that makes such materials, I do know that there is a rigorous review committee process by pharmaceutical company specialists to approve ads before
placing the marketplace. Thus a process exists for adhering to these guidelines among agencies and pharma companies, with the FDA regulations squarely in mind.

The findings are somewhat subjective, but this may introduce a cautionary note into the already existing process. Especially in light of the FDA "Bad Ad" program that so far has resulted in two warning letters.

Tracking privacy in online advertising

The climate is really shifting in online advertising the past few months. There is heightened awareness from the press on what behavioral information that digital advertisers are collecting. The government is responding:
the Federal Trade Commission has recommended universal “do not track” mechanism that would allow consumers to opt-out of the monitoring systems that follow users’ movements from site to site. For a gooda nalysis on the FTC ruling, see the Privacy Law blog article.

In addition, the leading web browser company, Microsoft, has announced that
the new Internet Explorer browser (IE9) –due out next year will include a “tracking protection” feature that allows users to limit third party data requests.

Meanwhile, online advertisers are trying to insure they are able to deliver effective ads, educating the public on the benefits. See the Wall St Journal blog on their planned campaign.

What are the consequences of increased privacy tools available to consumers? A Forbes magazine blogger notes that this will require marketers to be more intelligent and persuasive with messaging, and not merely rely on consumer background data stored in cookies.

I would say there is another consequence to online advertising and media placement: the premium will be contextual ad placement on relevant content areas, as opposed to websites merely statistically correlated with the advertiser's website.

One final thought ... how many consumers will take advantage of these new privacy features? There has been a mix the past few years.
The "do not call" consumer list gained a fairly high response once it came out. Email span opt out rates can get as high as 10 percent or more on a campaign, showing positive momentum. On the professional side, at first Physician "AMA opt out" of Rx tracking, on the other hand, was fiarly low at the start.

Uptake on privacy tool adoption will depend on publicity, ease of adoption, and the consumer mindset.

Advertising's future in the digital world

An interesting article this week in FastCompany about how digital is transforming the advertising industry. The perceptions are changing about traditional notions of "agencies of record," and marketing clients need to have digital, traditional, mobile all in place for consumer, professional, and payer to effectively launch a campaign.

How can this be achieved in the most nimble and cost effective way: some may say
via networks and sub-networks of conflict shops each with their own niche and specialty. Our CementBloc solution is a different: a single convergent agency across disciplines and customer segments, in one shop. With a strong campaign management group to insure the components and channels are working together, and with a multi-faceted analytics team to measure the synergistic effect across segments and channels.

Pharma media schedules for public view - wither violence?

It's remarkable to notice how a public advocacy group like the Parents Television Council can influence ED drug makers to publish their television media schedule for Viagra and Cialis. One can see how the two firms Pfizer and Lilly are focused on late night, sports, and news programs, essentially all in the evenings.

As a parent, I can empathize with other parents who may want to avoid certain content. However, personally, I feel more strongly about the rampant violence of commericals during afternoon broadcasts; even for actual network shows. Those seem impossible to avoid.

Measuring Marketing Promotions? -- Have a Plan

If you are about to launch a major marketing initiative, whether local or national, awareness or direct response, you probably are being asked to "measure the impact." or to "calculate ROI." Be aware that planning your measurement is part of planning the project itself.

One has to translate the business objectives of the promotion, or the RM program into measurable quantities that can assess whether those objectives are filled. Think in terms of the RM continuum. What are you trying to achieve?

* spread awareness: better have surveys to measure if they are aware, before and after

* get people to respond? Better have response mechanisms with data streams, and coded by source

* convert patients to drug? Getting doctors to write Rx? How is this data coming in?

* encourage advocacy? Make sure your advocacy tactics has a tracking breadcrumbs.


This sounds obvious as written, or in hindsight, but really this sort of planning requires a half day workshop of a cross-functional team.

At least.

The long tail of online media

How well do you understand online advertising, and where your media company is placing your banner ads and search box results?

Try an exercise... go to Google and type in a small business in your neighborhood.
Perhaps's "Joe's flower shop." You might get a search engine result like this where the results are about florists, and where the text box ads are also about florists and related items. So far so good. Now click on one of the local results, adn you might get a a directory listing link like this.

Notice the banner ads on your local flower shop? Not about flowers -- maybe the ads or for cars, sneakers, mobile phones, even pharmaceutical conditions or particular drugs. Why is this? You weren't looking for these things in your search.

This is a combination of several effects. One is that if you are logged in, and you have cookies enabled, there is demographic and behavioral information that can be leveraged for online media placement. (In fact, try the same exercise while not logged in to any email or social media systems). The other major effect is the media industry's design, a tactic called "the long tail." Note that Ford motors, Nike, or that pharma company did not particularly wish to target Joe's florist and other small businesses for media placement. But their media company may have paid an ad network to find people in a certain demographic: age, gender, spending levels.

Now, how likely is it that a person trying to order flowers from a local shop, will suddenly become interested in buying a car, or go to their doctor about a new pharmaceutical drug? The effect is more likely to be very subtle branding, but not much direct response.

So, if you are placing online media for a direct response consumer RM ad, be proactive and intelligent about where your media company is placing your banners. What percentage of your spend is on this "long tail" that is probably not going to get a very high response rate, due to lack of relevance to the search. If you are paying by the impression (CPM), it may be costly, if you are paying by acquisition (CPA), then perhaps the low hanging fruit can accumulate.

Journal of Case Reports -- Halfway to Social?

Much publicity about Elsevier creating a purely online International Journal of Surgical Case Reports, where physicains pay $400 to have their written case reviewed. Here is an example published case study, with figures. A recent Medical Marketing and Media article discusses this, including the motivation to build a case database for searching valuable cases.

Online advertising may be under consideration by Elsevier, though not currently implemented.


Author fee aside, this new journal is an advance in user generated content in the typically slow moving world of publications. In addition, this seems to only move halfway to achieve a more full potential of professional social media. Why not allow surgeons to post and have discussion threads about the cases, to learn from each other, and accelerate knowledge?

Deeper acquisition engagement and Yahoo Health

The latest Medical Marketing and Media issue points out that Yahoo Health has added interactive health search tools to engage patients longer on the third most popular health portal.

For an example, consider these resources available on a Yahoo health search for osteoporosis . Tests, self-care, and treatments are follow-on options. There are also banner advertisements for pharmaceutical products. Indeed, hope for Yahoo is also to increase contextual advertising revenue.

There are also features like find a doctor by specialty and zip code, and symptom checker. These features are all about deeper consumer engagement at the earliest stages of the patient journey: awareness and acquisition. That additional engagement can prepare patients to be more informed and receptive as they visit the physician's office.

Pharma DTC Spending Holds, and Digital Rises

Recent posts in Medical Marketing and Media notes that Pharmaceutical DTC spending has held firm in 2009, rising 1.9% to $4.5 billion over 2008 spend. Data is from the Nielsen Company. Considering reductions in sales force sizing, that means a relative rise in the percentage of spending in DTC in pharmaceuticals.

A closer look at these numbers brings insights by channel. Television spending is shifting from networks to cable, and magazine spending is down.

A note worthy trend is a rise in Internet ad spending of 31%, to $117 million. Of course, Internet spending is still small in the relative DTC marketing mix (less than a tenth of overall print or overall TV).

Still the rise shows that increasing numbers of pharmaceutical marketers are seeing these benefits of digital advertising:

Targeting: Online media can be targeted to consumers' behaviors, and their searches. It can also be placed within content areas geared toward disease education vs. specific products.

Direct response efficiency: On a cost per lead basis, search and direct response banners are very efficient.

Faster and Easier Measurement: Data on impressions, click throughs, and landing site activity comes in within hours and days after the campaign launches. This enables marketers to understand what their audiences really need and how well they respond to alternative offers.

Testing and Learning: In a related note, setting up parallel test cells for search or banner campaigns is straightforward using platforms like Omniture or Google Analytics. The rapid results noted above help you see which offer or creative is yielding the biggest response or most website traffic.

Rapid Media Optimization: One corollary to rapid data within a test and learn environment is enabling of rapid media optimization. Decisions can continually be made of what media changes to make.

These benefits should continue to make digital an ever increasing channel for consumer advertising and relationship marketing in pharmaceuticals in the future.