The FDA cares about your eyeballs.
Not in the sense you think: As an agency tasked with oversight of all medications – including optical treatments – of course they care.
But as a pharma marketer, you may soon need to know how much the FDA cares about eyes as they relate to your job. Specifically, the Agency is pursuing a study on animation in direct-to-consumer (DTC) ads to determine how eyes respond to movement – like in the awesome video ads you’ve been so marvelously creating.
Now, before you hem and haw about the FDA’s apparent goal to make the life of a pharma marketing exec a living hell – hear us out. There is actually a point to the study and the outcome may make your job easier.
Easier? Say it isn’t so!
Yes, it’s true. The FDA’s motivation behind the study on animation in DTC advertising is to determine how animation, when used in different ways, can result in higher or lower recall of ad details. The point is to make sure pharma PR people know how to avoid situations like Sanofi experienced in December 2016, when the firm received an untitled letter for its Toujeo spokes-dude: “Mr. Groove” got a little too groovy in the TV ad and the fast-paced animation created difficulties for consumers when attempting to process risk information.
But even before Mr. Groove, the FDA’s Office of Prescription Drug Promotion (OPDP) was inspired to dig deeper into the impacts of animation. In the October 2016 Comment Request (regarding how information for the study will be collected), the Agency mentioned that no studies have examined how animation in DTC ads impacts comprehension and perceptions of product benefits and risks. So, let’s study it!
What is OPDP looking at – or for?
The Office wants delve into two issues:
- Animation in Drug Ads: Does a viewer of the ad process the information differently when it takes the form of live-action, rotoscoping (tracing images frame-by-frame to create animation), or animation?
- Animation and Messaging: Does a viewer of the ad process the information differently when the focus of the animation is the person suffering from a condition, the disease itself, or the benefit offered?
Both questions focus on how viewers processes the information, which is key to comprehension of the details – and thus – the ability to appreciate the risks and benefits. The difference is that the first centers on the type of animation, while the second centers on what is being animated.
OPDP’s impression is that personifying characters through animation may interfere with communication of critical messaging on risks and benefits. Even as it increases engagement of the viewer, giving a disease human characteristics may not increase comprehension of the message. It’s the “may” and “may not” that the OPDP wants to turn into concrete “does” or “does not” through the study.
How is OPDP going to get answers?
Easy: Human guinea pigs and fake drug ads. The study design involves the Office hiring a professional company to create bogus DTC ads that are almost indistinguishable from the real-life spots for a chronic dry eye med and psoriasis treatment. The animation will incorporate different formats and personification components, and will be presented to viewers who have actually experienced one of the conditions.
NOTE: Don’t get your hopes up about this thrilling opportunity – the study specifically excludes members of the pharma marketing community.
What will OPDP do with the information collected?
I hope you’re sitting down: FDA Guidance! Yay, round of applause, fun times ahead. In all seriousness, Guidance documents aren’t so bad. Having an actual – albeit sometimes confusing and vague – statement from the Agency on its position and intentions is infinitely preferable to sitting around and waiting for a Warning Letter or Notice of Violation.
We’re going to keep tabs on the study and will provide updates when they become available. But until actual FDA Guidance on animation in DTC ads is published, it’s wise to at least consider the two issues that the OPDP is studying when creating animated ads.
Or maybe even conduct your own test: “Hey, Mom! How’s your psoriasis? Would you mind having a look at this ad? Does it provide sufficient information on risks and benefits?”
OK maybe that’s a little much, but you get the picture. As we wait for FDA Guidance, use common sense with animation and – as always – get input from your legal department.
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By Marc DeLeuw