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FDA Says No on Common Use of Ad Words

The FDA took widespread action against drug companies who have used the popular ad words on Google. FDA rules require that any mention of a drug name with its indication requires full fair balance. Drug companies have been short cutting that rule by assuming the one click away process for ad words was sufficient. For example consumers who type in a disease would see a two line side ad that gave the drug name that treats the disease with a one line description of its effectiveness. If they clicked they would go to the company site loaded with fair balance.

For example, type in birth control and get an ad that says how effective a named medication is for preventing pregnancy. That is illegal under current promotional regulations. Drug companies have been using these ads for a long time and FDA has finally ruled that short ads without fair balance are unacceptable, even with an easy click to fair balance.

On April 3, 14 letters referencing 48 drugs were sent out to many major drug companies telling them to cease and desist from this practice. Obviously, this makes ad words harder to execute. Drug companies will now have to make no claims about a drug or show any indication of what it is for.

Our editor of DTC Perspectives, Mark Tosh, got a response to some follow-up questions on the letters from FDA. They say drug companies can either do reminder ads with nothing mentioned except the drug name or use disease awareness ads. The FDA said that space limitation is no excuse for not including fair balance. They also said that many drug ads had followed the rules when using ad words.

I do not believe drug companies are going to lose much by dropping the indication or a brief claim line. If a consumer enters a disease name and a reminder ad appears with just a brand name, the consumer will still understand the brand is a likely treatment. The letters, however, were a clear warning that a new era is here with increased vigilance from FDA. I doubt drug companies will drop the ad word use and instead will comply using more reminder ads. Perhaps the loss of the indication tag line makes for fewer click troughs but I doubt a significant drop off. It will make an interesting analysis from Google.