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The Good, the Bad, and the Ugly of American DTC Prescription Advertising

This lecture is presented by David H. Kreling, PhD, Professor Emeritus of Pharmacy at the University of Wisconsin-Madison.

This segment will discuss different types of promotion used by pharmaceutical marketers, and will outline major drivers that shaped the American prescription marketing landscape and gave rise to direct-to-consumer advertising as we know it.

It is helpful to clarify the terms used in discussing prescription drug advertising.

Advertising is only one form of promotion.

Promotion, as defined in marketing textbooks, is any marketing communications by firms about or related to their products. Promotion efforts strive to inform consumers about these products or persuade consumers to purchase them.

Obviously, the intent of promotion from a marketer’s perspective is to increase sales and market size.

There are three major types of promotion used by drug manufacturers for prescription products. All of these types are considered marketer-controlled, since the method and the message is determined and controlled by the drug manufacturer.

Advertising is a non-personal promotion, usually in the form of mass communication conducted through paid media.

Sales promotion also tends to be non-personal promotion, and includes a tactical, short-term incentive designed to stimulate target market response, such as coupons or samples.

Personal or professional promotion, sometimes called personal selling, involves two-way conversation with potential purchasers to provide information and ultimately make a sale, or to build goodwill. A distinction of personal promotion is that it allows tailoring.

Traditionally, firms focused their efforts on physicians and the medical community. Historically, personal promotion via company-employed sales forces was a main emphasis in marketing. These efforts were often accompanied by sampling, to ensure uptake of new products.

Advertising was done more secondarily, particularly through print ads in medical journals.

In 1962, a revision to the FDC Act in the United States gave the FDA authority to regulate drug advertising. It defined labelling as any written, printed, or graphic matter upon or accompanying a drug product.

Advertising was seen as overlapping or closely aligned with labelling and needed to follow similar requirements—including adequate directions for use.

In the 1980s, American firms began to expand their advertising efforts to focus on consumers. Labelling requirements largely limited these ads to print media.

In the mid-1990s, the FDA provided a new interpretation of the regulations that made broadcast promotion more feasible. This allowed ads to include a major statement about the most important risks via audio or visual content.

The ads were also required to make “adequate provision” for access to the approved product manual and disclosures. That provision was satisfied by adding toll-free numbers to call, a reference to a website or print ad, or directions for consumers to contact their doctors.

It became more realistic to meet the educational content requirements in broadcast advertising, and direct-to-consumer ad spending increased substantially.

Prescription products still aren’t typical consumer goods. For most products, consumer ads motivate them to take action and purchase products. Consumer ads for prescription goods are an anomaly, since patients can’t purchase drugs of their own accord. Prescribers are critical for access.

This is called a directed demand, where the physician or prescriber directs the demand for the product and is necessary for the consumer to purchase it. This phenomenon contributes to the unique dynamics of direct-to-consumer advertisements for prescription drugs.

Proponents and advocates of direct-to-consumer advertising for prescription drugs have identified several consumer benefits.

Ads help consumers satisfy a need for health information, especially in the area of diseases, symptoms, and treatments. They can also increase awareness of conditions that exist in individuals and suggest that treatment may be possible.

Ads can encourage consumers to seek medical advice for conditions that might otherwise go untreated. Increased access to care and treatments can lead to positive health outcomes.

Advertising can speed adoption of new pharmaceutical advances and improve uptake of innovation.

There are additional subtle or secondary effects of direct-to-consumer advertising.

Television ads can also serve as reinforcement to remind prescribers about a product.

They often also offer substantial transparency about the degree of benefit that the product can offer, as well as incremental drug effects.

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