A content strategy pharma conundrum. (image via net_efekt)
The breakdown: How do you write a paid search ad for a pharma client that delicately balances FDA requirements, online space restrictions, drug benefits and adverse effects? Not an easy pill to swallow, but Jared Kelleher shows us one unique approach below.
I’ve been watching MadMen, and it seems to me that advertising was simpler then, than it is today; and that they used to drink a lot at work, though maybe there’s no correlation.
Then, you just whipped up wild ads like this over a couple martinis at lunch. Today, there are rules and regulations, general counsels, and protective bodies like the Consumer Protection Agency and the Food & Drug Administration, and we’re charged with knowing all the ins, outs and what have yous of the industry’s laws, bills, bylaws and amendments. I feel cheated, though not nearly as much as the pharmaceutical companies must feel.
Under an FDA rule called fair balance, if we’re promoting a drug’s benefits, we need to fairly balance those benefits with content about its risks. Pharma advertising evolved to adhere to the new ground rules; while watching the pretty people in the TV spots, we hear dozens of deleterious side effects as background voice-overs. In print, half or more of a drug ad contains the important safety information and adverse effects copy about sweaty hands, dry mouths, erections lasting longer than four hours, or in the case of black box warning drugs, thoughts or attempts of suicide.
Last spring, many pharmaceutical companies received letters from the FDA noting that their paid search ads were touting drug benefits, without equally messaging the drug’s risks. In paid search, fair balance rules are harder to play by. Try equally extolling the marvelous benefits and mysteriously unusual adverse effects of a drug in an ad the size of a matchbook.
Many drug companies responded by rewriting their paid search ads with benign, benefit-free, unbranded copy, or they pulled their paid search ads altogether. I’m no expert in pharma, but let’s consider a crazy idea: what if, instead of pulling our ads or rewriting them so feebly that neither the FDA nor our own customers know who’s running the ads, our paid search ads were explicitly about side effect and risks – no benefits.
Imagine, for example, Henny Penny Labs, a fictitious maker of the world’s leading worry and anxiety medications, most notably, WillyNilliex® – the #1 drug for nervous, jittery, cat-like behavior. Let’s say we’re charged with a keyword buy. Research shows we need a buy on symptoms such as: jitters, jittery, jumpy, goofy, tight, uptight, mad, mad as hell, angst, agita, and interestingly, verklempt.
Instead of getting upside down about what we can’t say about the tremendous benefits of WillyNilliex, we’ll run paid search solely on the drug’s rare-but-bizarre adverse effects, which incidentally, are likely the precise content many of our customers are looking for. Patients know what WillyNilliex is supposed to do. They want to know what it might inadvertently do – like possibly cause thoughts of suicide – good to know. Since there isn’t room in a paid search ad to balance benefits content with risks content, we’ll focus our test ad almost wholly on risks and side effects while mindfully communicating the drug’s indication:
WillyNilliex® Beats the Jitters
Side effects include hot dog fingers
evil eye, clown fear and more….
This sample is a bit out there, but it demonstrates how this transparent approach would benefit the user by being honest and forward with the side effects. Maybe it’s not quite a drug marketer’s dream, but the ad provides brand impression, piques interest and gives users access to content they supposedly want to see, all while seemingly coloring within the FDA’s lines.
OK, who wants a martini?