How “Treatments” Can Compliantly Address Audience Searches for a “Cure”
Pharma brands sometimes express concern that showing ads to users querying “cure” may imply the drug itself is a cure. Should a brand that treats (but does not cure) a disease serve ads to users who are trying to learn whether a cure exists? This is a nuanced question that deserves case-by-case assessment.
People often search for information about a cure for their disease. For products that are known to cure a given condition, the relevance of bidding on “cure” is straightforward. However, it’s widely understood that there is no known cure for chronic diseases such as cancer. Yet the concept of “cancer cure” has a high degree of relevance among the nearly 15 million people living with it in the US who ask questions of search engines like “can my cancer be cured?”
I propose three simple touchstones to guide the decision process.
1. Is it in the best interest of patients to see the information?
Consumers should have the opportunity to learn the answer from an FDA-regulated information source. Allowing terms that include “cure” will expose more consumers to FDA-regulated manufacturer sites – the only places on the internet required to present information that meets FDA’s standards for accuracy.
Implicit in this rationale is that the landing page should contain specific disease information. If a non-cure treatment option exists that may delay progression or mitigate symptoms, then the searcher would be well served by a regulated information source that informs them that there is no cure, but there is a treatment option.
2. Does the overall experience lead one to believe that the product cures the condition?
Like many digital media channels, you and I cannot predict the contents of a search engine results page (SERP) for a given search query.
Pharma marketers can take steps to ensure that the presence of their ad on the page does not create the misleading impression that their product is a cure by employing unbranded redirecting ads, as opposed to branded “reminder ads.” This ensures the brand name is not associated with the concept of “cure” before the user clicks. Once they are on the brand’s targeted landing page, they will only learn the brand’s name in the context of compliant website content.
3. Would it be acceptable to run a similar branded ad in a magazine exploring cures?
Suppose a health magazine popular among men 35-64 dedicated an entire issue to research efforts to find a disease’s cure. Would an ad for a non-cure treatment appearing in those pages violate FDA’s guidance?
Search results for a “cure” query would similarly produce cure-related content within which a non-cure ad is placed.
The FDA is not concerned with the mechanics of how ad-serving environments work. It is up to the ad copy to present the approved, balanced message in a compliant fashion. Exposing users to approved information about treatment options only enriches the user experience, and has potential to improve patient outcomes.
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