This will be my last post on this blog. As I walk off into the sunset to do this, someone new will take over for a while. I won’t spoil the surprise; check back tomorrow.
I’ve been writing about drug marketing for only three years, and blogging for less than that. But I’d still like to leave you all with some modest suggestions that would improve the promotion of drugs to consumers. I encourage your feedback and debate in the comments section below.
The BrandweekNRX DTC Reform Manifesto:
1. In TV ads for drugs, the FDA should ban disjointed imagery during side-effect warnings: One of the more compelling parts of the FDA’s review process was the presentation by Ruth Day of Duke University. She did a study showing that when drug ads listed benefits, the images on the screen matched the voiceover and moved slowly. But when side effects were listed, the images often became mis-matched to the voiceover and moved much faster or were more distracting. The result is that viewers find it more difficult to remember the side effects than the benefits. Once you know this, you’ll notice that this is a frequent aspect of drug advertising – as soon as they get to the bad stuff spots devolve into an avalanche of unrelated imagery.
2. Reminder ads should be illegal: Promoting a drug but not saying what it does or what its disadvantages could be? This helps neither the patient nor the doctor. The only health issue it promotes is drug companies’ bottom lines.
3. Product placement should be illegal, paid or unpaid: A product placement is essentially a sophisticated reminder ad (see above) and should be treated as such. When will the FDA wake up to this issue?
4. Drug company PR people should be properly trained to answer straight questions with straight answers: Here’s how the current kabuki show works: a reporter (or a blogger) calls up a drug company with legit questions about one its products. The pr person then asks for the questions to be submitted via email. The reporter submits a list of questions. The pr people ignore them. A day or so later (why does everything take more than 24 hours at drug companies? This isn’t the 19th Century!) the pr person sends an email to the reporter containing a single statement that fails to address the list of questions that the company asked to see, and often doesn’t really address the issue at stake. If changing this means firing traditional PR staff and replacing them with medical science liaison staff trained in pr skills, then so be it. But for the official spokespersons of drug companies to be unable or unwilling to talk in detail about their products indicates either ignorance or incompetence or, just as bad, lack of transparency.
5. Pharma companies should be required by the SEC to break out their promotional costs: Currently, drug companies don’t have to say anything about how much they spend promoting drugs. They mix those numbers in with their selling, general and admin budget line. They do break out their R&D costs. But for some reason their promo costs remain a mystery. This is because marketing costs tend to be roughly double R&D costs. PhRMA frequently bleats that new drugs cost in excess of $800 million to develop. Give them the benefit of the doubt – but remember that such a drug will burn through $1.6 billion in ads, sales rep salaries and CME grants across its lifetime. Who ultimately pays for that? Consumers and taxpayers. Asking for transparency on this is not burdensome. Bristol Myers Squibb already does it in part (although I’d like to see something a little more detailed.)
6. FDA should require relevant head-to-head studies for second-to-market drugs: If companies want to launch a new brand, they currently have to prove to the FDA that the drug is both effective and safe. But they don’t necessarily have to provide data about the drug’s effectiveness or safety as compared to its key competitors in the market. Rather, new drug studies are often based on older, generic or less sophisticated drugs on the market. This is why doctors in crucial areas of practice – such as cancer – still lack evidence of whether Femara is more effective, and under what circumstances, than Arimidex. Neither AstraZeneca nor Novartis has dared to study both drugs against each other, even though they both treat the same thing. What does this have to do with advertising? Ads tend to be based on claims for the drug, but currently most DTC is laughably vague. “Take control of your life,” “Take action,” “Now you can do something about it,” and so on. If there were head-to-head studies on record with the FDA you’d soon see DTC advertising become a lot more specific about whose drugs are safer and whose are more effective. And we wouldn’t have fiascos such as this one, where doctors weren’t recommending certain cancer drugs because they weren’t being paid enough to administer them.
7. FDA-mandated transparency in Continuing Medical Education: Drug companies should have to report into a web-based form on the FDA’s web site the total amount of money they spend on CME, which companies they funded to provide it, and which categories they provided CME funding in, with each entry broken into dollars. Then, once a year, companies should have to file a PDF detailing every single CME payment they made to every single CME company, broken down by dollars, purpose, event and date. Medical education should no longer be like the Wizard of Oz sitting behind the curtain. Companies should have the right to educate doctors about anything they want, but there should be full transparency about it.
8. FDA-mandated transparency in grants and donations for non-profit groups: Again, as above, drug companies should have to properly report in detail who they funded, how much they funded and when they funded, on a single public web site. That will allow patients and doctors to more objectively evaluate the statements of various pressure groups on health issues. Ever wondered why Planned Parenthood was so gung-ho about hormonal contraception? Could it be because the Robert Wood Johnson Foundation, funded by J&J stock, is a major donator to its various affiliates? (Here’s just one of many.)
9. FDA mandated transparency for payments and gifts to doctors: The laws of Minnesota and Vermont, which require all drug company payments and gifts to individual doctors be recorded and made transparent, should be adopted nationally. The public has a legitimate interest in knowing whether doctors are speaking as objective experts or as paid sock puppets. So many doctors make it into media coverage because their expertise has been leavened by consultancy fees on the very issue they’re being asked to comment neutrally upon.
10. FDA mandated transparency in prescription-writing habits: Some doctors have gotten annoyed at the fact that sales reps can check scrip databases and find out how much of each drug they write. Reps often know more about doctors’ scrip habits than doctors do. The doctors are wrong on this issue. In just the same way that the public should be able to see which doctors are on pharma payrolls, there’s an obvious public interest in being able to see whether doctors prescription habits correlate with the payments they’ve received from drug companies.