PhRMA’s New “Guiding Principle” #10 for Direct-to-Consumer Advertising states:

“DTC television advertising that identifies a product by name should clearly state the health conditions for which the medicine is approved and the major risks associated with the medicine being advertised.”

This, as other commentators have noted, would eliminate “reminder ads” that promote a drug by name but do not mention the indication or side effects (see Pharma Marketing Glossary for a more extensive definition).

I didn’t think this was such a big concession by pharma when I reviewed the guidelines a couple of days ago (see “PhRMA Finalizes DTC Principles“). Since then, however, several news items and comments from pharma experts have characterized this as a “meaningful” step in the right direction.

Traditional “media types” or TV advertisers love reminder ads because, in their view, they raise “frequency” without costing a lot. (It’s called GRP or “Gross Rating Points” extension; GRP is “[calculated] as a percent of the target market reached multiplied by the exposure frequency. Thus, if you get advertise to 30% of the target market and give them 4 exposures, you would have 120 GRP.” (Thanks to

The frequency advertising technique is not as effective as it once was (see, for example, “Out-of-the-Box Marketing: Will It Work for Pharma?” There I review Seth Godin’s book “Permission Marketing: Turning Strangers Into. Friends And Friends Into Customers”, which is critical of the traditional Reach and Frequency model of advertising.)

I find it interesting that some pharma marketing professionals and journalists are making such a big deal of Principle 10. This may be because reminder ads are often thinly disguised full-blown product ads without the messy fair balance requirement.

Reminder ads are just too tempting for pharma companies to use to make claims about the efficacy of the products without mentioning side effects. In April of this year, for example, the FDA ordered a Levitra “reminder” ad off the air essentially because it was not a reminder ad at all! (See “FDA orders Levitra ad off the air“).

The ad featured a flirtatious actress asking “In the mood for something different?…[Levitra] is the best way to experience that difference.”

The FDA interpreted this as making a superiority claim for the treatment of erecticle dysfunction and said “FDA is not aware of substantial evidence or substantial clinical experience demonstrating that Levitra is superior to other (erectile dysfunction) treatments.” FDA says that reminder ads can only call attention to a drug, not say how to use the drug or how well it might work.

So let’s hope that reminder ads will go the way of the dodo and thereby eliminate another loophole for “push-the-envelope” marketers to exploit — to the detriment of the pharmaceutical industry’s image!