Fair Balance Issues in Mobile Pharma Ads: FDA’s Thoughts – and a Rare Easter Egg

As many of us in pharma marketing land were enjoying our Fourth of July celebrations, some folks over at the Journal of Medical Internet Research decided to rain on all of our parades. Well, not really – but an article published in the journal on July 4, 2017 included some pretty sobering information:


There are some in the healthcare comms space that are doing it wrong when developing drug ads for mobile devices.


Yikes. After all we do to stay in compliance with FDA regulations and read up on Guidance in certain marketing channels, we don’t yet have it together when promoting products via smartphones and tablets. Fortunately, the JIMR article merely states the results of an investigation conducted by experts over at the FDA’s Office of Prescription Drug Promotion; it’s not a binding rule. In any event, marketers should certainly perk up their ears because there’s some fantastically useful information here.


And by the way, did we mention that the JIMR piece contains an Easter Egg? Oh yes, they did! It’s so much fun when seemingly stoic experts with letters like “PhD” and “MPH” after their names add a little bonus for pharma PR execs to enjoy. Or maybe it wasn’t even intentional, but it’s a killer tip either way!


But, first….


An Overview of the Findings: The methodology for the study was pretty straightforward. The panel evaluated 51 healthcare communications distributed through mobile devices, and analyzed the associated landing pages. The experts looked at content and format of the information in the context of drug benefits and risks.


Of the total 51 ads, 21 were product claims – the ones we know all too well because we’re required to balance benefits and risks when mentioning the drug by name. The balancing act didn’t go so well in many cases:


  • One-quarter percent of these ads required scrolling to see benefits information, while a whopping 95 percent required the user to scroll to see risk information.
  • There were 19 of the 21 ads that presented both benefits and risks; however, 95 percent of these positioned benefits first AND 47 percent used a bigger font for benefits.


In addition, 35 of the total 51 ads linked viewers to a landing page. One-quarter of these landing pages had zero risk information. Scrolling was an issue with landing pages as well, as only 8 percent required navigating to benefits details and 51 percent required scrolling to see risks.


JIMR Investigation Conclusion: A veritable tsk, tsk. There are serious implications for FDA fair balancing rules. These ads may be misleading to the consumers that view them, because the viewer has to “work,” i.e., scroll or click to a landing page. They may not be getting critical information. And that’s when healthcare marketers start sweating about receiving a nasty letter from the FDA.


Still, We Promised an Easter Egg…


OK, so in the true spirit of the Easter Egg, this may not totally qualify. It’s not all that hidden. It’s more of an outright statement from the authors to “Do this; not that.” And here it is:


Reminder Ads


No, they’re not some new-fangled approach to pharmaceutical advertising. Reminder ads have been around for years. This is ad content that gives the name of the drug, but not its use – based upon the assumption that the viewer already knows the primary usage.


The critical point for distributing reminder ads through mobile devices is that this type of promotional material doesn’t require risk information.


Indeed, the JIMR article authors specifically stated that reminders “may be suited to the mobile space” because of the lower bar on risk details. They also noted that some of you do “get it” with reminder ads in the mobile space. The investigation reported that 22 percent of the content they viewed fell into this category.


Obviously, a reminder ad cannot be used for drugs that carry serious risks and other limitations may apply. After all, there are rules at the stoic FDA – Easter Egg notwithstanding. Still, there are certainly opportunities for pharma marketers. And there may be opportunity for a future ISEBOX pharma blog on do’s and don’ts for reminder ads (there are many) – so stay tuned!


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