Healthcare Comms Group Developing Code of Ethics for Marketing: Our Thoughts

Good news, healthcare comms! Things are looking up for the life sciences and the marketing agencies that serve them, after confirmation of the new FDA head Scott Gottlieb in May.


He’s a busy guy, with frequent Tweets regarding policy announcements on topics ranging from regulation of innovative tobacco products and speeding up the generic drug approval process – to the opioid epidemic and advancements in medical devices.


One noticeably absent topic: Addressing false and misleading drug promotion in pharma marketing. That would be the fly in the ointment for many life sciences advertisers, as we could all use a little more direction with our content – especially in light of the FDA’s molasses-like pace in publishing Guidance documents.


But the lack of Tweets from Gottlieb regarding false and misleading ads has a silver lining (after all, we promised you good news). In the absence of FDA action, the Coalition for Healthcare Communication is stepping up to the plate. The CHC is an organization dedicated to promoting the free exchange of information in life sciences, recognizing that the First Amendment does apply in this space. Dissemination accurate scientific and medical information to healthcare providers and consumers is critical – even as the “false or misleading” standard must be balanced with free speech considerations in pharma firm-sponsored content.


So the CHC has decided to be proactive, instead of waiting for the FDA to speak up. The organization’s Executive Director, John Kamp, recently announced efforts to develop a code of ethics and self-regulatory guidelines to assist pharma marketers in their efforts to publish accurate, timely information for healthcare professionals and the general public. Guidance from a reputable healthcare communications organization? Yes, please!!


And there’s more. A code of ethics will also help healthcare comms in one area that continues to be the bane of our existence: Trust in what we do. Many consumers don’t trust life sciences marketing content, according to a 2017 Harris poll: Only 9 percent of US consumers believe pharma puts patients over profits (ouch!).


In the same poll, about two-thirds of US consumers say pharma firms must demonstrate ethics in addressing healthcare. If it’s ethics they want, an ethics code is what they’ll get!! But while we wait for Kamp and the CHC team to release their official self-regulatory guidelines for advertising in healthcare, we’ve got a few principles to propose…


Proposed Code of Ethics for Marketing


  • Healthcare communications and PR must strive to achieve truth and adhere to high ethical standards in advertising messaging. Given that advertising is commercial content, it should be created in accordance with the same accuracy standards as news.


  • Pharma marketers must exercise the highest level of personal ethics in creating and disseminating healthcare communications. This point addresses the role of professionals on a personal level. When you believe in what you do and appreciate the importance of your work as a pharma marketer, you want to do your personal best in carrying out your responsibilities.


  • Pharma PR should make a clear distinction between marketing communications and other types of content. If the consumer isn’t aware that your content is marketing, as opposed to news or entertainment, it can create confusion and mislead them. By blurring the lines, you’re treating your audience unethically.


  • Healthcare comms should ensure privacy is not compromised through marketing messages. In the world of online marketing – across all industries, not just pharma –technology allows for behavioral advertising, i.e., delivering marketing messages to a user based upon their online behaviors. You can’t go online these days without data being collected on what you search for, your shopping habits, and what you post on social media.


We marketers have an ethical obligation to avoid compromising the information we collect from consumers. There’s a big difference from seeing that couch you crave on Wayfair show up in your Facebook Newsfeed – and being presented with ads related to the meds you take for depression or other sensitive condition.


It wouldn’t be surprising to see similar principles show up in the CHC version of the pharma marketer’s code of ethics. Just remember: ANY code or self-regulation guideline is ALWAYS subject to FDA regulations and Guidance. You still need to comply with the law. But you can take the healthcare marketing ethical high ground when you incorporate these moral principles alongside your legal duties.



 We conducted a survey of journalists and media to see how Pharma is doing getting information out. Check out the results to see how you can improve.

2017 survey results: Drug companies failing to meet journalists' needs 


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