As you may be aware, the FDA issued warning letters to a number of pharmaceutical companies earlier this year regarding their use of search engine advertising to market prescription drugs. The FDA’s finding was that these text ads (35 characters headline and 70 characters over two lines of body copy) did not adhere to the standards of warnings and risks fair balance that they require in other advertising media (TV, print, etc.).
This past week, the FDA conducted hearings on how they might best regulate internet marketing (including advertising and social media) and took testimony from of number of vested interests including Google.
Google posted its presentation and here are a few observations I thought might be of interest:
- Google makes a good case regarding the growing use of search and online research for health-related information – 4.6B searches; 3x growth in 3 years – and actions taken as a result. The point is that people are going to the internet and the FDA needs to take this bigger picture look at how consumers receive and process medical information and modify its policies regarding advertising and other forms of internet marketing to provide the best possible access to health information.
- Google uses sharp declines in click-through rates as an indication that text ads since the FDA warning are “less transparent and relevant.” This is undoubtedly true. I have to point out though that these declines in CTR’s also mean significant drops in pay-per-click revenues so don’t think Google is solely altruisticly motivated.
- Google’s recommendation is to have fixed warning/risk information included in the text ad with 62 characters available for modification. The examples they provide are for searches on the product brand name. But what if the search is “generic” instead like on “seasonal allergies?” Also, this would seem to provide pharmaceutical companies with a significantly greater advertising footprint (and likely competitive advantage) over other advertisers, for example, lifestyle websites promoting similar topics.
Clearly, the hearings were just the start of the discussion and there will likely be changes/modifications before anything is finalized some time in the future.
And this leads me to a final and bigger question: how can government agencies like the FDA keep up with the fast-evolving sphere of the internet and provide time-appropriate oversight?