FDA is proposing a”National Direct-to-Consumer Advertising Survey” of 1765 and soliciting comments on its plan in the Federal Register [Docket No. FDA-2016-N-0544].

Recall that the FDA is currently doing or planning at least two other studies of Direct-to-Consumer (DTC) advertising:

  1. “Spousal Influence on Consumer Understanding of and Response to Direct-To-Consumer Prescription Drug Advertisements”; FDA-2014-N-1819). For more on that, read “Does Your Spouse Influence Your DTC Viewing Experience?“) and 
  2. “Experimental Study of Direct-to-Consumer Promotion Directed at Adolescents” (FR # FDA-2013-N-1151). For more on that, read this Pharma Marketing News article.

FDA surveyed patients about their experiences with and attitudes toward DTC advertising in 2002 (here). Why is FDA proposing the new study now?

“Numerous changes have affected the DTC landscape since 2002,” said FDA, “including declines in print readership, the rise in online prescription drug promotion, and self-imposed industry guidelines for DTC advertising. These changes may have affected consumers’ exposure to different kinds of DTC advertising and its influence on their attitudes and behaviors. The purpose of the National Direct-to-Consumer Advertising Survey is to collect updated insights on consumer experiences with and attitudes towards DTC promotion of prescription drugs. This study will build on previous research by recruiting a wider range of respondents, weighting the data to make it nationally representative, and ask a wider range of questions about DTC promotion, including in online formats.”

I emphasized the “including in online formats.” Perhaps FDA’s study will yield more information about how online DTC advertising compares with TV or print DTC advertising. Whether or not that is the case and whether it will have any impact on regulations of online advertising remains to be seen.

Interestingly, FDA Based plans to use monetary incentives to recruit study participants. FDA will mail in advance two $1 bills ($2 total per sampled respondent) along with the initial invitation letter as a “gesture to encourage response and maintain data quality. Offering a small token of value to participants establishes a latent social contract and subsequent reciprocity.”

LOL! Although it is a common argument among pharma marketers that tokens of value (e.g., free lunches) given to physicians do NOT establish a “latent social contract,” the FDA obviously doesn’t hold that point of view, at least when it comes to consumers.

FDA’s survey contains questions about respondents’ knowledge of FDA’s authority with respect to prescription drug advertising, their exposure to DTC advertising, their beliefs and attitudes about DTC advertising, and the influence of DTC advertising on further information search and patient-physician interactions.

Some of these questions may already have been answered by my friend Richard Meyer who did a survey of over 3,000 TV viewers about thier attitudes toward DTC advertising. You can learn the results by listening to this Pharma Marketing Talk podcast: