Search engine marketing, also called pay-per-click (PPC) advertising, is an effective method of connecting your brand with potential customers. PPC advertising offers companies the opportunity to reach an audience at the exact moment they are seeking a solution, by presenting ads directly above or to the right of the organic results. While organic listings are more trusted, they are also more difficult to achieve, especially when launching a new product or website. So while growing your search engine ranking placement (organic SERP) can take several months to a year, PPC advertising can deliver immediate traffic to your landing page.
This type of advertising is also extremely targeted; targeting capabilities are very sophisticated, you can target by location, by device, time of day the ad is displayed and more. Plus it is one of the most measurable forms of advertising available. Every single aspect of your campaign is tracked from the number of click conversions, cost per conversion, etc. making it very easy to understand your return on investment (ROI), make adjustments and improve your campaign.
Many medical device companies have become gun-shy when it comes to running PPC advertisements, and rightfully so. The FDA is not afraid to send out warning letters alerting healthcare companies that they are in violation of acceptable marketing practices – PPC included.
What's acceptable according to the FDA? Answer: Very little.
In the summer of 2014, the FDA finally issued some draft guidance on Internet marketing. One document, titled “Internet Social Media Platforms with Character Space Limitations – Presenting Risk and Benefit Information for Prescription Drugs and Medical Devices,” addressed how companies should discuss risk and benefit information on platforms where communications are limited to a specific amount of characters. This includes Google’s paid search option and platforms like Twitter.
The FDA stated that an ad must provide adequate explanation of the risks associated with the product and provide the full name of the drug or device. Yet, this is practically impossible given the maximum 35-character limits of search advertisements and presents companies with a few big challenges.
- Strict requirements are likely to discourage participation in this platform, so information available on any medical device could actually become more limited and not reach the public where they expect to find it.
- This opens the door for foreign suppliers or natural, homeopathic treatments (who don’t fall under FDA guidelines) to increase market share. Yes, companies can file the trademark paperwork with Google to stop their brand name being used, but these other companies can still run ads for symptoms, conditions, etc. and gain market share.
What's a company to do? Answer: Choose the best option for you.
I suppose the most compliant and most conservative thing a company can do is simply choose not to run PPC at all. They could file their trademark paperwork with Google to protect their brand name while beefing up their organic SEO. This way, hopefully, they gain share of unbranded keywords – like conditions or symptoms.
However, winning the SEO game takes a lot of time and resources, so this isn’t all that realistic for most companies.
Some companies, pharma companies in particular, have been operating under an assumed “one-click rule” in which the side effects are listed within one click of an ad rather than in the actual ad text. This is an interesting interpretation, but not sanctioned by the FDA.
Many companies are finding a way to run PPC ads by looking at the FDA’s guidelines around the “help seeking” ad category. Help-seeking ads describe a disease or condition but do not recommend or suggest specific drugs or branded treatments. They use unbranded URLs that redirect to the branded website.
This tactic also passes muster with Google, whose policy states:
- Pharma advertisers are allowed to use an unbranded URL that redirects to their branded website
- Pharma advertisers must own this unbranded URL and it must be working (if a user were to enter it directly into their browser, it must redirect to the advertiser’s branded or working URL)
There is a downside to this option: a higher chance for consumer confusion. A consumer seeking information on headache pain, for example, might view a help-seeking PPC ad as confusing or even deceptive, if the link simply redirects to a brand page, instead of a disease-specific website.
The bottom line is that the FDA says ads must provide adequate explanation of the risks associated with the drug or device and provide the full name of the product all within a 35-character limit. So if you want to comply 100% you simply can’t run PPC because this is impossible.
However, if you’re open to the help-seeking option, you can effectively launch a PPC campaign in a manner compliant with the FDA and Google.
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