We are living in a post-Vioxx world where DTC can no longer exclusively mean direct-to-consumer advertising (DTCA). Today
it must mean DTCC—direct-to-consumer communications.
Peter J. Pitts
Why? Because reform, while presented as voluntary, is in actuality being driven by the winds of the perfect storm—the 2004
presidential election season, the emergence of drug importation as a populist political issue, the Medicare Modernization
Act, and drug safety (as personified through the issues of clinical trial transparency and Vioxx). A grand slam of highly
charged issues made it not only possible, but also predictable that the media—and, as night follows day, politicians—would
begin portraying Big Pharma as the new Big Tobacco. And DTC, being as it is the most public face of the industry, found itself
squarely in the bull's-eye of pundit satire and political outrage.
It was into this arena that PhRMA launched its voluntary Guiding Principles for DTC. And this long delayed document needed
to be more than a transitory inoculation against the DTC desperados in Washington and their allies in Congress. It needed
to make a difference.
Winston Churchill said, "Americans always try to do the right thing—after they have tried everything else." If the pharmaceutical
industry wants to change its image—from salesmen to scientists—on the Hill and in homes nationwide, it's time for Big Pharma
to turn from pyrrhic victories to long-term strategies. And, in this respect, the new DTC guidelines, even though voluntary,
are an important step in the right direction.
Today there is a new pharmaceutical Theory of Relativity: R3=DTCC. Now, in order for you to understand the elegant physics,
allow me to first explain the three "Rs" of pharmaceutical DTC communications.
The three "Rs" are derived from PhRMA's 15 Guiding Principles. The first "R" is for reaffirm. Eleven of the fifteen principles
fall into this category. In essence, they say that pharmaceutical companies will follow the rules and guidances set forth
by FDA—and that every new ad will be submitted for review. I can already hear the groans from DDMAC.
The second "R" stands for redeploy. Guiding Principle number 10 calls for the de facto banishment of reminder ads, resulting in the need to redeploy the dollars and tactics previously handled by these obnoxious
little billboards. While there are many strong and potent arguments as to why drug ads truly advance the public health—by
destigmatizing diseases (such as depression), reinvigorating doctor-patient conversations, assisting in compliance, and uncovering
previously undiagnosed conditions earlier in the disease process—there are no good arguments for why reminder ads, in any
way, advance the public health.
Other things that will need to be redeployed, according to Guiding Principle number 13, are television ads that discuss lasting
erections and satisfying experiences. Currently, those ads are limited to adult viewing hours, whatever that means. Seriously,
folks, will primetime television featuring programming about sex be any better or worse without commercial breaks featuring
advertising about sex? While most average Americans probably agree that banishing erectile dysfunction advertising from family
viewing hours is a good thing, they were all already probably too busy doing something else—like watching Desperate Housewives and Family Guy—to notice.
The third, final, and most important "R" is rethink. It is here that the rubber really meets the road. This is the hard "R,"
the "R" that challenges the pharmaceutical marketing mind. The "R" that demands a redefinition of long-term thinking from
the end of the quarter to the end of the quarter century.
Consider number three: "DTC television and print advertising which is designed to market a prescription drug should also be
designed to responsibly educate the consumer about the medicine and, where appropriate, the condition for which it may be
prescribed." Also number 14: "Companies are encouraged to promote health and disease awareness as part of their DTC advertising."
The operative phrase here is, "promote health and disease awareness."