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This latest action from the FDA has resulted in confusion, a need for counsel, and conjecture at what might be next.
VP OF DIGITAL STRATEGY | IGNITE HEALTH
This latest action from the FDA has resulted in confusion, a need for counsel, and conjecture at what might be next. In the short term, pharma pulled their paid search efforts, vacating the top sponsored listings and lowering the overall bid price to command a high rank within the hierarchy of these results. This immediately opened the door to an unsavory mix of natural remedies, blame-obsessed lawyers, and unsubstantiated Canadian pharmacies to move up and occupy these top sponsored results—potentially posing a greater public health concern with respect to the information that patients are likely to receive.
A review of the violations yielded two very challenging results. First, the letters bring up specific grievances (omission of risk information, inadequate communication of indication) that are often impossible to correct given the confines of paid search advertising, leading many to question the FDA's full understanding of this medium. The "one-click rule," which had always served to connect a paid search ad to a Web site that included the full indication and safety information, was pronounced dead. And second, there is no formal guidance from the FDA on what is acceptable in terms of paid search or any other form of online promotion. By far, the biggest consequence of these recent letters was to leave pharma marketers with a disquieting feeling of "what's next?" Is paid search just the tip of a giant digital iceberg that could include many of the influential new channels that pharma has started to embrace? Will our latest efforts on YouTube, Facebook, and Twitter be the next to receive letters of violation? Will this send us scrambling to abandon the vision of creating a sense of community with our patients?