Tips for Responsible Pharma Keyword Governance
This is the first in a multi-part series about “promotional peccadilloes” – topics that often trigger a perceived conflict between good regulatory compliance and effective marketing, and our perspectives on best practices to address them.
Let’s talk about low-hanging fruit. What if your website were foregoing 50% or more of its potential qualified traffic because you were not bidding on keywords used by your target audience members using search engines to seek information about their condition?
Based on its outsized and ever growing role in driving digital engagement for pharma, paid search should be the last place brands accept compromise when it comes to effective, transparent marketing. But with search engine marketing (SEM) long in the bullseye of regulatory scrutiny over marketing in space-constrained environments, prudence is warranted. The direction delivered in 14 letters from the FDA to pharmaceutical companies running violative campaigns in 2009 was a seismic event for digital pharma, resulting in significant messaging restrictions within the paid search channel.
Did You Say Keyword Restrictions?
Unlike ad copy, keywords were a non-factor in the 2009 letters – conspicuous by their omission. The FDA went a step further in 2013, explicitly stating that keywords do not have to be submitted on 2253s. That said, there are important principles that govern the responsible use of keywords in the context of paid search campaigns – some are grounded in simple common sense, while others provoke healthy debate and deliberation. Below we explore some typical examples of the latter together with our perspective, with an eye towards finding the sweet spot – the convergence of accurate, best-practice regulatory compliance and effective pharmaceutical audience communications.
Best-Practice Keyword Selection for Pharma Paid Search
Getting down to basics, paid search campaigns, at their core, are the product of keywords and text ads. Keywords define the audience to be targeted, and text ads are the marketing message – comprised of a headline, description, a URL and a few available types of “ad extensions”, themselves additional ad copy and links to site content. In an effort to adhere to the spirit of FDA regulations, we often see pharma brands and MLR teams not only reviewing text ads, but also expressing concerns or prohibiting outright the use of certain keywords. Sometimes this results in keeping potentially valuable keywords out of SEM campaigns for fear of their being misconstrued as making a claim or otherwise misleading their audience. Let’s look at three common examples:
1. Related disease terms that do not match the brand’s indication
Marketers of a drug treating a subset of those with a given disease may be concerned that employing the general disease name as a keyword (without qualifying the subset) broadens their implied indication. Let’s consider a drug indicated for type 2 diabetes employing the keyword “diabetes,” without the qualifier “type 2.” Some patients have type 1 diabetes, a disease this drug is not indicated for. Is “diabetes” by itself a compliant keyword?
People living with diabetes often search for information about the disease without specifying type. Google nevertheless generates millions of search results in response to each query. Results for a broad “diabetes” search may thus generate results for drugs that treat either form of the disease.
If a person with type 1 diabetes searched for “diabetes treatment options”, neither search engines nor pharma marketers have any way of determining whether the searcher is a type 1 or type 2 patient. If an ad for a drug treating type 2 diabetes is served to a type 1 patient as a result of this search, the fact remains that the user searched for “diabetes treatment options” and found the full set of available results about the exact topic they searched for.
For a type 2 diabetes treatment campaign, a strategy of bidding on a long-tail phrases like “type 2 diabetes” while omitting general “diabetes” searches significantly reduces the ad’s discoverability among its target audience. Consider that 90-95% of all diagnosed diabetes cases are type 2, yet “type 2 diabetes” only accounts for 40% of total monthly Google searches for either “type 2 diabetes” or “diabetes”. Omitting “diabetes” would result in a 60% drop in search impressions with no provable difference in targeting accuracy. The inescapable implication is that many patients who would benefit from treatment with the drug will simply not find the information because the ad is not served.
2. Competitive brand or product names
Marketers may be concerned that serving an ad to someone who searched for a competing brand implies they have identical indications, creating the appearance of off-label promotion. As written by Dale Cooke of PhillyCooke Consulting, marketers worry that “intentionally targeting a population that is not indicated for using my product on label could be evidence of an intent to market the product off-label”. Drugs for unrelated indications should indeed not be used as keywords, just as those indications themselves would not be appropriate. A brand should also take care not to bid on the name of a competitor approved for both its own indication and a separate, unrelated indication.
Also avoid bidding on the names of competing drugs that treat the same general disease state but with non-overlapping indications. If your product treats breast cancer associated with BRCA 1 mutations while a competitor treats breast cancer with PTEN mutations, then patients using the competing drug are not an appropriate audience for the marketer’s drug. On the other hand, if a competing drug treats breast cancer of all types, then its name is fair game for brands that are indicated for subsets of breast cancer patients to bid on.
Cooke draws a strong parallel for decision-making about keywords, suggesting the FDA’s position is “consistent with offline practices because the function of keywords is analogous to a media buy for an offline print ad. The keywords selected determine where the ad can show up, but they aren’t themselves part of the ad.” For example, placing a women’s health treatment ad in a magazine read by 18-35 year-old women clearly does not imply all readers are appropriate patients for the treatment – neither does serving approved search ads in response to broad queries about a disease state effectively “broaden the indication”.
In both cases, the targeting criteria selected may improve the composition of the audience reached within the means provided by the respective channels, while the ad copy presents the approved, balanced message in a compliant fashion. When people who have a reason to search for a competing brand also have a reason to know about our brand, then the competitor’s name could be an appropriate keyword.
3. Queries including the disease term plus “cure”
Brands sometimes express concern that showing ads to users querying a disease “cure” may imply the drug itself is a cure.
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 is 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 cancer in the US and their loved ones who ask questions like “can my cancer be cured” or “can cancer be eradicated?”
What happens when a cancer patient turns to Google with these types of questions and begins with an open ended search on “cancer cure”? The engine returns 89,600,000 indexed web pages. If the user were patient enough to spend five minutes reviewing each result, her research would take 852 years to complete!
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. We propose three simple touchstones to guide the decision process:
1) Is it in the best interest of patients to see the information?
One can certainly make a case that 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 high standards for accuracy.
Implicit in this rationale is that the landing page for such queries should contain specific disease information including whether it has a cure. 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 (of the ad and the page) lead one to believe that the product cures the condition?
Like many digital media channels, one cannot predict in advance the contents of a search engine results page (SERP) for a given search query. Additionally, listings will vary not only by keyword but also between individual users based on time, location and personal browsing behaviors. 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 for such queries, as opposed to branded “reminder ads”. This ensures that the brand name is only associated with the concept of “cure” after the user clicks and is redirected to the brand’s targeted landing page for that keyword – in the context of its approved, compliant website content.
3) Would it be acceptable to run a similar branded ad in a magazine exploring cures?
The third touchstone brings back the analogy of offline ad placement as one final cross-check. On the traditional side, one can certainly imagine hack publications touting false cures for certain conditions, and strong brands are wise to distance themselves from low-quality editorial environments, as their presence may imply endorsement of misleading information. Indeed, the web itself includes some dubious information which may find its way into search results. There is a case-by-case judgement call to be made here based on the prevalence and severity of such claims in the market. That said, if audience reach, relevance and editorial quality are reasonable criteria for media placement, then marketers should never discount the fact that Google’s search engine has become the world’s leading information source because it excels at doing one thing – connecting people effectively with the information they are seeking.