UPDATE April 6 (original post follows):

Seems like the times have changed already. In the week after I wrote this, the FDA has cracked down on paid search ads. On Friday, April 3, the FDA sent letters to 14 companies specifically about misleading search marketing ads. As you saw in this post, no one was really quite sure how to interpret FDA rules for search, but they made it pretty clear in these letters. If you have have the drug name and an indication, you’d better have fair balance. Same as every other promotional medium. The story of these letters broke on April 3 and included a few examples. One such ad was for Biogen drug Tysabri. The quote from the article:

“Biogen received a warning letter for its multiple-sclerosis drug Tysabri. The ads say ‘A Multiple Sclerosis Treatment That’s Different from the Others’ or ‘Satisfied with your MS Medication or Looking for Something Different?’ but don’t include any risk information.

“Their casual approach to Tysabri treatment is extraordinary in light of the potentially lethal risks of the drug and the stringent controls over its distribution,” the FDA said in its letter to Biogen on March 26. The letter was posted on the agency’s Web site Friday.”

The most critical part of all these letters for pharma companies is as follows: “Biogen’s ad includes a link to the Web site for the drug, which does contain the relevant risk information. The FDA said the link ’does not mitigate the misleading omission of risk information from these promotional materials [bold added].’ “ That is, the one-click rule is dead. Just because you have the risk information on the page your ad links to doesn’t mean you don’t have include fair balance. So, for all the complaining I do about the FDA not being clear on digital promotion guidelines, this seems pretty clear to me. Check out my original post, which contains some more things for pharma marketers to consider when placing paid search ads.

Original Post

I’ve been meaning to write this post for a while and haven’t gotten around to it. Someone at work today reminded me of it when they asked me a very simple question (or so it would seem) about FDA rules regarding paid search marketing. (For the sake of today’s post, I’m referring to search engine paid search such as Google AdWords.) The question was this: “Since you have to include fair balance when you show the drug’s name and what it is used for, how come there are all these paid search ads that do both with no fair balance?” Here’s an example of one of these:

There you see a paid ad (in the tan box) from Femara along with “Breast Cancer.” Femara is indicated for breast cancer, so by including the name of the drug and what it is used for without fair balance they are in violation. Right? Wrong?

The answer is I have no idea and neither does anyone else for sure. The FDA has never formally issued guidance here (a pet peeve that I’ve blogged about before). The rule that many companies seem to use is the “one click rule” (good review here from Catalyst). Many companies use this rule almost like it’s a formal FDA policy, but it isn’t. Basically, the rule is that if the fair balance information is one click away from the ad, then you’re okay. Or are you?

At the end of last year, Diovan received a warning letter for a banner they used that contained no fair balance (hat tip to John Mack’s post about this issue). They were applying the one click rule. The FDA didn’t care. Two things to consider though: this was a banner and not just a simple text ad like AdWords and Diovan has a black box warning meaning it’s got a whole set of special promotional rules to follow. So, you can’t really say this is the end of the story. Fact is that thousands of pharma ads are served up on Google each day that, by letter of the law, are in violation. The FDA has to know this and lets it go, so there has to be some informal nod of approval there…maybe.

Enough of that. In this post, I want to do two things. One, convince you of the value of paid search and two, show you some examples of what to do and what not to do. 

One: Why You Should Care About Paid Search

I’m going to use Google AdWords throughout this post, but know that the same rules apply to Yahoo! or MSN or any other network that wants to serve your text ads. If you have no idea what AdWords is, you can start with this primer from Google.  Very few pharma marketers I know really understand paid search and why it’s important. Typically, the buying and planning for paid search is relegated to the “e” team or is completely outsourced to a media buying agency. While this may be fine, you still need a working knowledge of what’s going on. Here are a couple of bullet points on why you should care about search as a channel for marketing:

Big numbers, right? Here’s why search marketing is so important and why it works: Many people go online with a problem. Problems need solutions. This is what Google’s results, both paid and organic, are supposed to be. Solutions. If you search for “hotel in San Juan,” we can reasonably assume your “problem” is that you need to find a hotel in San Juan. The solutions might be organic results of some major hotels in the area and the paid results that might include something as simple as “Cheap hotels in San Juan.” Consumers are looking for Google to provide a solution and Google is letting you help them provide it (at a cost, of course).

Clearly this is how patients use the Internet. They have a problem (e.g., a condition they are managing) and they want solutions. These solutions can come in many forms and you need to be sure that you’re part of the list. Here’s an analogy for you: paid search similar to someone who goes to a grocery store looking for diapers. They already know their problem (out of diapers…a major problem), but they may not know their solution. This person gets to the shelf (Google’s search results page) and then picks out a solution (a specific brand of diapers). If your brand is not appearing in paid or organic search results on the first page, then you’re not “on the shelf.” It’s hard to be selected when you aren’t on the shelf.

Okay, so by now you’re convinced. Paid search is good. One more thing to consider, it’s highly cost effective. With AdWords, you only pay when someone clicks on your ad. So, you’re only getting people that found some appeal with your ad. They’re interested in your solution. So, you’re not wasting money paying to display ads for people who don’t care about your solution. You pay when they click. That’s good news and bad. You pay when they click. Each time someone clicks, money comes out of your budget. The question then is “did you get your money’s worth”? Here’s how you can ensure that you do.

Two: What To Do and What Not To Do

I’m going to be as diplomatic as I can here in providing some constructive criticism. When I show an example, know that this is just one of probably hundreds that are making this same error, so if you’re site or campaign is here, know that you’re in good company. Paid search is still a new skill for many pharma marketers, so mistakes are going to be made. Let’s just figure out some ways to ensure that they don’t keep happening. I’ve broken the areas you should focus on into three sections.

“Fulfil the Promise”

This means that when you promise something in your ad, make sure you deliver it. If you don’t, the patient will simply leave immediately and you wasted your money at best. At worst, you can create someone who has a very poor perception of your brand…not something any pharma brand needs. Here are the first paid and organic search results for “breast cancer” again. You should know that each time someone clicks on a paid search ad for “breast cancer” it’s going to cost between $1 and $7. It all depends on what the competition is bidding at that time. $7 a click is quite a bit to have people leave as soon as they arrive.

So, does Femara fulfil the promise? They say they are going to allow you to “Review Treatments.” When you click on the ad, you get to this page. See it for yourself here and below.

It’s the Femara homepage and, right away, I don’t see anything about reviewing treatments. There is a link to “Treatment Options” on the left, but why didn’t I get automatically sent to that page? Rule one: if you promise something then deliver it. Part of this is ensuring that you don’t direct every paid search ad to your homepage. Direct them to the page that matches the information you promised in your ad. 

To give Femara the benefit of the doubt, I checked this “Treatment Options” link to see if this allows us to “Review Treatments.” For one section, adjuvant therapy (one place where Femara is indicated), here’s what was included:

Not exactly “Treatment Options” when your treatment is the only one listed and far from letting me “Review Treatments” as the ad indicated.

Patients Like Me, normally one of my favorites, is guilty of the same rule violation. They have two versions of basically the same ad for the search term “fibromyalgia” (Google lets you experiment which works best, which I highly recommend). Here they are:

Subtle difference, but one offers you a survey when you click and the other doesn’t. This is a great way to see what people are more interested in and what will get them to click your ad and come to your site. However, both of these ads send you to the same generic fibromyalgia landing page. There is no survey. At best, an honest mistake, at worst a bait-and-switch. Unfortunately, this is very common in AdWords, but people don’t like to be tricked. They clicked on your ad for a reason and expect to see what you promised. Don’t waste your money if you’re not going to fulfil the promise.

“Switch-A-Roo at Your Own Risk”

The “switch-a-roo” is pretty common on AdWords. This involves including one URL in your ad and then automatically redirecting the user to a different URL. Here’s an example:

So, I searched for “Cholesterol” and got back these three paid search options. The first one sounds pretty good. I want to know how to do all this stuff…lowering my cholesterol and such. The Site URL sounds good too: GetCholesterolInfo.com. I want to get info and it sounds non-biased. I’ll go with that. But where does the patient go? To the Crestor brand site.

The person clicking this ad may be fine with this or they may scoff at being sent to a pharma brand site when they thought they were going to a third party information site based on the URL in the ad. Again, you might lose someone immediately and you’re wasting money. Let me also say that there is nothing illegal or unscrupulous about using these masked URLs and redirects. They are well within Google’s guidelines. In addition, they don’t violate the letter of the FDA law since the ad doesn’t contain a brand name. So, they are likely “less” in violation than the versions that include a disease state and a brand name. Likely, but who really knows.

Crestor does get higher marks than Femara (disclosure: I used to work for AstraZeneca, makers of Crestor, but they’re getting a little rough treatment, so you know I’m not too biased). They fulfil the promise to a much higher degree. They offer in their ad “ways to lower your LDL cholesterol” and they direct you to a page in the section of their site called “Living a Healthy Lifestyle” with information about diet, exercise, and stress management. They didn’t just dump the patient on the homepage and require him to find his way to this info.

So, I said this section is called ”Switch-A-Roo at Your Own Risk” and I mean it. There isn’t anything wrong with using these masked URLs, just know that some people might not appreciate them. As I said before, Google let’s you experiment. Try different ads and track the bounce rate of those clicking the ads. Bounce rates essentially let you see if people leave your site before clicking anything else. Is the bounce rate really high with the masked URLs compared to the real URLs? If so, you might have a problem with upset people leaving right away when the figure out this is not what they expected. Test, test, test.

“For All That Is Decent and Holy, Buy Your Brand Keywords”

I didn’t include the first part of the rule initially, but added it in my second draft to emphasize the point. I’m not even going to explain this rule, I’m going to see if you can figure out the problem from this picture. This is the search result for “Lipitor:”

Figure out the problem yet? For all the fighting pharma does over Canadian imports, especially Pfizer’s based on its history, you’d think that pharma would take care of this little problem. The two top positions for paid search go to Canadian pharmacies. If someone was just prescribed Lipitor, they probably go online to check it out a bit more even before they fill the prescription. They search for “Lipitor” and find a simple way to buy your drug from Canada. That’s not in the marketing plan.

There might be a really good reason why Lipitor is not buying its brand keywords. They may have exceeded the budget for the day, one of these other companies outbid them, or Pfizer may have chosen to not bid on “Lipitor.” Whatever the reason, it’s still a rule. Always own your brand name on AdWords. Don’t let anyone else dictate the message. By letting someone else have the top spot (you can outbid if you need to), you’re giving them the opportunity to tell your story. You don’t allow that in any other marketing channel, so don’t allow it here.

Those are the rules. Follow them to get started in paid search if you haven’t already or follow them to improve what you’re already doing. As always, if you don’t have anyone at your company or agencies who you feel can do this properly, then contact me. Remember if your company was mentioned in my post about Pharma’s Getting the Message, I’ll help you for free. All the companies mentioned in this post are on the list (hint, hint). 

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