In case you haven’t realized it yet, the FDA is not very well-versed in the intricacies of new media, which may be why it took the agency so long to deliver guidelines for pharma’s use of social media (see the PharmaGuy Social Media Timeline for details).
A good example of FDA’s lack of digital expertise is its recommendation for the use of Google Adword site links. “Ad site links,” says Google, “add value to your existing AdWords ads by providing additional links to specific, relevant content deeper within your site map.”
FDA suggested that drug adwords — even adwords for drugs with black box warnings — can use site links to “convey the most serious risks associated with [the drug], including the boxed warning and additional warnings about fatal and life-threatening risks.”
The guidance document includes this example of ad for the hypothetical drug Headhurtz:
|FDA example of Google ad with site links. Numbers are FDA’s counts of characters used/maximum characters allowed. Click on the image for an enlarged view.|
“FDA would not intend to object to this sponsored link format,” notes the Agency in its guidance document. Unfortunately, if a real drug ad followed this advice, the FDA might renege on its promise and “object.”
Why is that?
Listen to the following Audio Snippet of a podcast interview of Dale Cooke, Principal, PhillyCooke Consulting, who describes the problem better than I can. He also explains how to properly use Google ad site links if you wish to truly comply FDA regulations.
|Don’t Follow FDA Guidance on Use of Google SiteLinks|
In this 2-minute audio snippet, Dale Cooke, Principal, PhillyCooke Consulting, talks about the limitations of Google Adword Sitelinks for complying with FDA’s June 2014 guidance on space-limited communications.
Cooke explains why FDA’s recommendation for using Sitelinks should not be followed by pharma brand advertisers.
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Listen to the full interview of Cooke here: “Create Squeaky-Clean Pharma Ads: Tricks & Tips to Avoid FDA Letters”