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An Eye On Google: Re-engaging with digital marketing in response to recent FDA warnings

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Whitepaper on the May 2009 FDA guidelines for Pharmaceutical Paid Search. Includes overview, definitions, guideline interpretations, implications for marketers, and how the industry will need to reply in order to remain compliant.

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  • As for organic search the 'important safety information' on each page definitively cause duplicate content issue. Am I right? If so how to overcome that issue? Any thoughts on that?
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An Eye On Google: Re-engaging with digital marketing in response to recent FDA warnings

  1. 1. An Eye on Google:Re-engaging with digital marketing in responseto recent FDA warnings Sara Weiner Contributions by: Senior Manager, Interactive Strategy Croom Lawrence and Carlen Lesser RTC Relationship Marketing 1055 Thomas Jefferson Street, NW Suite 200 Washington, DC 20007 202.625.2111 RGB (screen match)
  2. 2. An Eye on Google:Re-engaging with digital marketing in response to recent FDA warningsSara Weiner, RTCRMRecent warnings by the FDA and long-standing concerns regarding digital pharmaceutical advertising havemade it increasingly difficult to safely develop interactive campaigns.1 RTCRM believes that success will notcome by deciding whether or not to do paid search or banner ads, but rather in the creative and experientialexecution of all digital strategies.In reviewing the current landscape, it is apparent that branded and unbranded pharmaceutical effortsalike can be employed on the digital platform, while still maintaining FDA compliance. That said, rich mediaprovides the best method for both delivery and user experience when FDA compliance is a concern.Overview• The FDA has warned that paid search copy without safety information creates a misleading experience for patients, establishing a precedent of concern about all digital tactics• For paid search, the issue is primarily in the functionality and logistics of the search engine technology• There are best practices in paid search that can protect your pharmaceutical brand from noncompliance• The one-click rule may still apply in some scenarios• Rich media banners are the best approach for materializing a patient’s digital experience alongside safety informationI. FDA Warns Pharma to Change Search PracticesIn early April 2009, the FDA sent 14 pharmaceutical companies warning letters regarding their paid searchpractices, suggesting that their ads were not in compliance with FDA standards.2 The FDA called theseads “incomplete” and “misleading” due to the lack of risk-related detail displayed in the ads.3 While someof the drugs included in these warnings were Black Box, some were not, creating implications for allpharmaceutical marketers.The companies that received letters in April were: Biogen Idec, Sanofi-Aventis U.S., GlaxoSmithKline, ForestLaboratories Inc., Cephalon Inc., Bayer Healthcare Pharmaceuticals Inc., Johnson & Johnson PharmaceuticalServices, Pfizer Inc., Novartis Pharmaceuticals Corp., Genentech Inc., Boehringer Ingelheim PharmaceuticalsInc., Merck & Co., Inc., Hoffman-LaRoche Inc., and Eli Lilly and Co.1 U.S. Food and Drug Administration, Center for Drug Evaluation and Research. “Warning Letters and Untitled Letters to Pharmaceutical Companies 2009.” (April 2009) http://www.fda.gov/cder/warn/warn2009.htm2 ibid.3 ibid.An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 1
  3. 3. The current standard for pharmaceutical paid search is to provide risk information as quickly as possible upona patient’s entry to the branded website. The general “rule” is to provide this information within “one click”from the ad. While the FDA has never issued any official guidelines for this issue, marketers have looselyapplied this approach to mean that safety information may either be on the landing page in completedocumentation, or listed as a link on the landing page. 4 This latter option results in two clicks rather thanone, but most marketers consider this approach acceptable.In these April 2009 warnings, the FDA appears to be mandatingthat some risk information should be denoted in the search Search Ad Formatad copy itself. This mandate is in direct conflict with the searchengines’ ad copy restrictions, which do not allow enough space • Title: 25 charactersto accommodate this information. The major search enginesrequire that marketers adhere to 95 characters (including • Description line 1: 35 characterspunctuation and spaces) in their ad copy.5 • Description line 2: 35 charactersThe ad copy requirement is actually broken down even furtherinto 25-35-35 characters, on three lines. This restriction hasalways proved challenging for marketers, as it leaves little roomto promote product qualities, offers, and brand reputation.For pharmaceutical marketers, this challenge becomes even greater, as they must balance two things:1) compliance with the FDA, and 2) the search engines’ ad copy requirements.Generally, pharmaceutical marketers provide safety information along with any branded drug messaging, butwhen one is limited to only 95 characters of text, including this lengthy information becomes impossible. This iswhy the pharmaceutical industry has adopted the one-click approach.The issue, based on the recent FDA warnings, has now become twofold: 1) does the one-click rule still apply, and2) how do advertisers ensure that their search copy is in compliance by using only 95 characters of text?Unless the FDA is suggesting that pharmaceutical companies abandon branded Search Engine Marketingaltogether, the one-click rule would still have to apply. There is no current mechanism for distributing safetyinformation in search ad copy, so this information must be located on the website, for now. We will reviewhow to manage pharmaceutical paid search copy, but first let us consider technological changes that mightmeet the FDA’s in-ad copy suggestion.4 Mack, John. Pharma Marketing Blog. “Death of the One-Click ‘Rule’ or ‘Received Precedent’ or Whatever!” (December 9, 2009) http://pharmamkting.blogspot.com/ 2008/12/death-of-one-click-rule-or-received.html5 Google AdWords Help Section. Advertising Policy: Editorial & Format. (2009) http://adwords.google.com/support/bin/static.py?page=guidelines.cs&topic= 9271&subtopic=9277An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 2
  4. 4. II. It’s Google’s MoveAs the FDA continues to mandate such restrictions, RTCRM believes that the search engines themselves willneed to make concessions to help facilitate the delivery of risk information in paid search ads.The FDA’s stance is that important safety information needsto be readily available to the patient when they are exposed Proposed Ad Formatto any branded drug messaging. Though they have not issuedofficial guidelines, their recent warning letters imply thatthe one-click rule is not a sufficient patient experience. Let’s Brand Official Siteexplore what they mean. Learn about benefits and risks of treating condition with Brand www.Brand.comCurrently, if a user reads a search ad but does not click through, Full Safety Information Herethey will never see the risk detail that is only found on thewebsite. They will only be exposed to the ad copy and maywalk away thinking that this is all they need to know about thebrand. RTCRM believes that a technology fix is needed in orderto solve this problem. The search engines could provide a second link for “safety information” inthe context of the search ad copy. This would make patients aware that such information is readilyavailable, while fulfilling both the current industry mandate of “one click” as well as the newFDA-suggested in-ad copy.The question then becomes: If it is a technology issue, who is responsible for implementing this change?Most likely, the answer is Google. It represents 63% of U.S. search share and arguably controls and engineersthe paid search landscape.6 Google has the ability to most effectively change the ad copy requirementsfor regulated industries like pharmaceuticals. Precedent demonstrates that Yahoo! and MSN may followsuit if Google implements this change. When MSN launched its search platform in 2005, it copied Google’s95-character limit (a calculated way to make it easy for Google advertisers to transfer their campaigns toMSN). Similar to MSN, Yahoo! changed its character limit to mirror Google’s when it launched Panama in2007 (most likely in a much-needed move to allow itself more ad space and thus more revenue). Currently,in 2009, all three major engines have similar ad copy requirements, and there is a precedent for the othertwo to follow Google.So, it’s Google’s move here. Google has an opportunity to develop unique ad copy requirements andfunctionality for regulated industries such as pharmaceuticals. While increasing copy length to permitinclusion of long-form safety information would likely lead to a poor user experience, including a second linkin the ad copy could solve the problem.6 comScore. Core Search Report, February 2009 vs. January 2009. (March 13, 2009)An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 3
  5. 5. III. Will Google Do It?Google is not going to move quickly on this, though it will surely receive requests from a number of agenciesand marketers. Google, understandably, prefers to maintain control over its marketplace and will wait untilit sees a business case for implementing this second link before doing so. By providing too much informationup front in the ad, Google would lose out on its revenue maker – clicks. Google does not make money when aconsumer only sees an ad. Google makes money when a consumer clicks on ad, a system called cost-per-click(CPC). Since a pharmaceutical marketer only has to pay when a patient clicks on a search ad, Google can onlymake money if this patient reads the safety information and still clicks on the ad. It sounds reasonable enoughthat a patient would do this, but if we consider the amount of detail that is actually in the safety information,including the risks and warnings, this approach may actually drive patients away, and thus keep them fromclicking on the ad. So Google, to its own detriment, could possibly make less money as a result of the in-adcopy requirement.Google could offset any loss in revenue by developing a supplementary cost structure, such as an additionalflat fee for this second link. It would be more likely, however, that this new link would be subject to the sameCPCs as the rest of the search ad. Another consideration in evaluating the plausibility of this change is Google’sadamancy about user experience. The entire purpose of its algorithm (other than revenue) is to create arelevant, seamless user experience. To develop this second link, Google would have to believe that it creates abetter user experience. To do this at no extra charge, Google would have to see the altruistic value in providingthis information to patients at the point of exposure. A pilot program would quickly prove whether thisapproach was: 1) better for the patients’ experience, and 2) still lucrative for Google. Surely, a short test wouldnot hinder Google’s revenue forecast; consider all the incremental dollars that pharmaceutical marketers wouldspend if they could invest in FDA-compliant search marketing.Google has, indeed, already made some concessions for the pharmaceutical world regarding display URLs,though they go against both traditional pharmaceutical advertising principles and, surprisingly, againstGoogle’s usually adamant stance on user experience. First let us review Google’s basic editorial regulations,which demand that:“Your display URL must accurately reflect the URL of the website you’re advertising. It should match the domain ofyour landing page so that users will know which site they’ll be taken to when they click on your ad.” 7Despite this publicly stated regulation, Google has seemingly found a rationale for an exception to its ownrule: It permits pharmaceutical advertisers to implement a fake unbranded URL that does not actually exist,but rather redirects to a branded site. RTCRM disagrees with this exception to the rule and believes a fake URLcreates a larger issue for pharmaceutical FDA compliance. Manipulating a patient into landing on your brandedsite via unbranded material violates a number of pharmaceutical standards. We will review this issue in detailin section VII.7 Google AdWords Help. Advertising Policy: Display URL. (2009) http://adwords.google.com/support/bin/static.py?page= guidelines.cs&topic=9271&subtopic=9280An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 4
  6. 6. IV. Should Pharma Go Unbranded?While advertisers are waiting for a functionality that actually allows them to adhere to this FDA implication,they still need to manage their paid search campaigns. Leading with an unbranded approach is your safest bet.RTCRM employs similar strategies in its pharmaceutical unbranded TV practice. Here, an unbranded TV spot isused to drive to unbranded Web content that includes an offer.Follow-up fulfillment is usually branded and patients becomepart of a long-term communication stream. For pharmaceuticalsearch marketers this approach would translate to an aggressive The Case for Branded Termsunbranded keyword and ad copy campaign that drives to arobust unbranded website. • Most-qualified patients, actively interested in your brandThe concern, however, for all search marketers, including • Increased awareness and brand recallpharmaceutical companies, has always been in the qualityof the traffic from these unbranded search terms. Generally, • Drive ROIunbranded terms have lower conversion rates than branded • Presence for navigational search andterms, simply because these consumers are not as far along misspellingsin the consideration or purchase cycle as a branded-term • Patients follow same response funnelsearcher. The win here would be in managing unbranded as general marketterms to the extent that they can efficiently and effectivelyreplace branded terms.From the other standpoint, some marketers may wonder why they should even consider branded efforts at all;in general, branded terms drive mostly navigational clicks and the FDA letters directly warned against brandedads. So, for pharmaceutical marketers, what is the value in branded traffic?RTCRM believes that branded search terms have not been completely taken off the table and, wherepossible, should remain as part of any search strategy. Research has shown that branded terms driveincreased ROI and the most qualified of potential customers. The traditional concern is that as a marketer yourbrand website will appear in the organic search results for a branded search term anyway, so why should youpay for additional ad space with branded terms? There are two arguments to be made here. The first is thatincreasing visibility in search results improves a customer’s awareness and consideration. In fact, an Enquirostudy in late 2007 showed a 7% point increase in purchase intent for branded queries that displayed both anorganic and paid listing in the same results.8 The second argument to be made is that searches on brandedkeywords generally come from a marketer’s most qualified customer target. It is likely that searches on brandedterms are in response to exposure to other marketing tactics. By removing branded paid search listings, you areactually decreasing the chance to capture these potential customers, and most likely these are the customerswho are most ready to convert to your brand’s offerings.98 Enquiro Search Solutions. “The Brand Lift of Search: Enquiro Online Survey and Eye Tracking Study.” (July 2007) http://www.enquiroresearch.com/campaigns/ TheBrandLiftofSearch.pdf9 Brooks, Nico. Atlas Institute. “Sponsored Search: How Much Are You Paying for Your Customers’ Navigational Behavior?” (2007)An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 5
  7. 7. The same principles should apply to pharmaceutical campaigns, and there have been some recent studies thattouch upon this, though further research should be developed to analyze specific conditions. In particular, astudy performed by Google and comScore in 2007 found that undiagnosed diabetes patients took on average6 months to perform their research.10 It was also discovered that diabetes patients, both diagnosed andundiagnosed, use search engines to find both condition (76%) and treatment (34%) information throughout thiscycle, indicating they need unbranded and branded ads alike to complete their research.11In the end, it is up to each individual pharmaceutical company and its legal team to decide whether tomove forward with branded terms, but there is clearly an ROI case to be made for keeping them as partof any search campaign.V. An Eye Toward ROIWhether moving forward with only unbranded terms or Basics for Runningwith branded terms as well, RTCRM recommends setting Paid Searchgoals and objectives before any paid search engagement.Marketers should look to develop keywords and ad copy • Set goals and create measurement planthat will serve these goals. Additionally, a measurement • Develop keywords, ad copy, andplan should be agreed upon and an analytical platform landing pagesshould be implemented before the launch of any search • Launch campaign and monitorcampaign. It is important to understand that, due to the Quality Scoredynamic landscape, search is not a “set it and forget it” • Manage toward goals and optimizemedium. Search marketers should be prepared for frequent accordinglymanagement and optimization of keywords and copy(and even landing pages) to meet objectives.VI. Implementing Best PracticesOnce an approach has been outlined and goals are in place, keywords and ad copy should be evaluated forFDA compliance. It is important to understand how paid search works, in order to properly assess keywordchoice and copywriting strategies.Google created an algorithm that displays search ads based on relevancy and monetization. Google usesa Quality Score to calculate whether your ad should be displayed.12 This Quality Score is made up of a numberof related elements that, combined, allow the search engines to measure the value of displaying your adscompared with displaying other ads in the same competitive set.10 Google and comScore. Patient Pathway Study. (April 2008)11 ibid.12 Google AdWords Help. Advertising Policy: About Quality Score. (2009) http://adwords.google.com/support/bin/answer.py?hl=en&answer=10215An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 6
  8. 8. Included in these elements is your CPC, and the more a marketer is willing to pay, the more likely onemight be able to offset a poor Quality Score. There are, of course, undisclosed factors, but according toGoogle’s help section:“In general, the higher your Quality Score, the lower your costs andthe better your ad position.”13 Elements of Google’s Quality ScoreIt is important to recognize that these elements are dynamic andthe competitive landscape changes frequently, so • Relevance of the landing pagecampaign metrics may change daily. Overall, the net-net isthat a search marketer must deliver a better Quality Score • Relevance of ad copythan its competitors, and must do it within the extremely • Historical performancelimiting 95-character ad copy structure. • Competitive landscapeIn order to acquire this high-quality score, there are basic best • Click-through rate (CTR)practices to follow in writing search ad copy. Most important • Undisclosed factorsin any approach is to ensure both relevancy and a cohesive userexperience. Ad copy should not promise one thing and drive to awebsite that provides something else. The engines hate this, andso do consumers. Best Practices in Writing Search Copy• Use the searched-upon keyword in ad copy to increase relevancy, both for the consumer and the algorithm• Use “Official Site” in copy to create trust with the consumer and add credibility to the ad• Use concrete calls-to-action to drive CTR and aid the consumer in their research• Use display URLs that match the domain of your website• Ad copy should respond to the query and tell the consumer what they will get by clicking on the ad13 Google AdWords Help. Advertising Policy: About Quality Score. (2009) http://adwords.google.com/support/bin/answer.py?hl=en&answer=10215An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 7
  9. 9. VII. Relevancy vs. The FDAThese current practices work very well in the telecom, retail, automotive, and financial verticals, but inpharmaceuticals, copywriting for paid search ads is not as clean cut. Relevancy gets trickier, and your 95characters of ad copy need to work harder. While the above practices still apply, FDA regulatory nuances needto be incorporated. Relevancy still matters, but ensuring compliance with the FDA’s standards, and keeping inmind its recent perception of misleading materials, matters more.Due to the short nature of search copy, it’s better for pharmaceutical marketers to use the 95 characters ofad copy as a drive-to-site strategy and to avoid using it to sell or explain the drug.If pharmaceutical marketers choose to move forward both with branded and unbranded paid search efforts,there are guidelines to consider when writing the ad copy.FDA Compliance in Writing Pharmaceutical Search Copy*• Do not use a brand name/URL and the indication in the same ad copy without mentioning risk• Do not run branded copy with unbranded keywords, nor unbranded copy with branded keywords• Use brand name and mention of the generic molecule in same copy• Do not use unbranded display URLs that redirect to branded sites*based on FDA guidelines for reminder ads, product claim, and help-seeking adsAs with other verticals, RTCRM recommends that, overall, pharmaceutical marketers follow the same approachas previously outlined, including using the branded or unbranded keyword in the search ad copy, wherepossible, to increase relevancy. Specifically, for pharmaceutical marketing, it is important to keep in mind thefollowing guidelines in order to comply with the most recent FDA positioning:a) Do not use a brand name and the indication in the same ad copy 14: In the case of pharmaceuticals, branded keywords should call up general branded copy that does not mention any indications. Use of the brand name should be run alongside mention of the generic molecule. If someone searches on Brand it would be safest to display something similar to: “Brand Official Site. Full Generic Molecule. Safety Information Here. www.Brand.com.” This ad copy must redirect to the branded site. In this example, a marketer maintains trust by using “Official Site,” relevancy by including the keyword in the ad copy, and FDA compliance because there is no misleading information or indication noted.b) Do not use unbranded keyword with branded copy (and vice versa) 15: In the case of pharmaceuticals, unbranded keywords should not call up branded copy. This inverse combination puts the patients in a position to assume that the branded drug treats the unbranded query. Similarly, the reverse situation, which would use a branded keyword with unbranded copy, may create an assumption of treatment or indication.14 U.S. Food and Drug Administration, Center for Drug Evaluation and Research. Statement of FDA Before Special Committee on Aging, United States Senate. (Sept. 2005)15 U.S. Food and Drug Administration, Center for Drug Evaluation and Research, FDA Draft Guidances Aim to Improve Health Information. (Feb. 2004)An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 8
  10. 10. For the purposes of the following chart and discussion, we will use osteoporosis as the condition under evaluation: Search Ad Copy Risk Evaluation KeywordRisk Sample Ad Copy Landing Page Issue Query * Similar to accepted reminder ads Brand Official Site. * Not permitted for Black Box brands Full Generic Molecule.Low Brand www.Brand.com * Safety information should be on landing page Safety Information Here. (one click) www.Brand.com * Requires legal approval on case-by-case basis * Acknowledges risks, but doesn’t provide Brand Official Site. material up front Learn About Benefits and Risks ofMid Brand www.Brand.com * Safety information should be on landing page Treating Osteoporosis with Brand (one click) www.Brand.com * Requires legal approval on case-by-case basis Osteoporosis Management * Similar to accepted help-seeking ads osteoporosis Learn Tips and Get Support to HelpLow www.unbranded.com * Requires legal approval on case-by-case basis management Manage Your Osteoporosis * No safety information needed www.unbranded.com * Unbranded to branded material, similar Brand Official Site. to regulated product claim ads osteoporosis Full Generic Molecule. * Misleading indication experience forHigh www.Brand.com unbranded keyword search management Safety Information Here. www.Brand.com * Need safety information available * FDA letters warned against this Osteoporosis Management * Unbranded to branded material, similar to regulated product claim ads osteoporosis Learn Tips and Get Support to HelpHigh www.Brand.com * Misleading landing page for unbranded management Manage Your Osteoporosis keyword search www.Brand.com * FDA letters warned against this Osteoporosis Management * Unbranded to branded material, similar to regulated product claim ads osteoporosis Learn Tips and Get Support to HelpHigh www.Brand.com * Misleading Display URL for unbranded management Manage Your Osteoporosis keyword search www.healthybones.com * FDA likely to warn against in future There are some nuances to consider here, and pharmaceutical companies should discuss this issue thoroughly with internal legal teams. Overall, RTCRM recommends reviewing all current ad copy to look for instances where messaging may be construed as being “misleading” or including broad generalizations, per the recent warning letters.16 16 U.S. Food and Drug Administration, Center for Drug Evaluation and Research, Warning Letters and Untitled Letters to Pharmaceutical Companies 2009. (April 2009) http://www.fda.gov/cder/warn/warn2009.htm An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 9
  11. 11. Another consideration, briefly mentioned in section III, is display URLs. Google has issued an exception for pharmaceutical marketers allowing them to use a fake, unbranded display URL that drives to a branded site. Many pharmaceutical marketers implement this strategy, and Yahoo! Search Marketing has considered adopting it as well.17 However, RTCRM believes that the fake, unbranded display URL practice creates a misleading and deceptive user experience. It is unlikely that the FDA will continue to permit this practice much longer, because it appears to be in direct conflict with current branded and unbranded advertising guidelines. The following example may help explain why RTCRM feels that this practice is in violation of current FDA guidelines. Let us say that a patient searches on a health term such as osteoporosis and sees an ad for www.healthybones.com. Here, the patient understandably thinks he or she is clicking on an ad for unbranded content. With their interest captured, they then click on this fake, unbranded display URL and are redirected to a branded website. This is not what the patient asked for, nor was it their expectation when they clicked. Instead the patient is manipulated into exposure to branded content. This violates traditional pharmaceutical advertising principles, the recent FDA stance, and arguably Google’s positioning on relevancy and user experience. Remember, the basic best practice for search marketing is to create as much relevancy as possible between ad copy and Sample Search Ad: Fake website content. In fact, Google directly states in its editorial Display URL* policy that: Osteoporosis “Your ads and keywords must directly relate to the content on Learn Tips and Get Support to the landing page for your ad. When users see your ad, they Help Manage Your Osteoporosis should be able to understand what kind of product, service, or www.healthybones.com other content they will find on your site. Products or services *Sample paid search ad reflecting misleading experience promoted in your ad must be reflected on your landing page; ads can be disapproved if a promoted product is not offered or available for sale as promised.” 18 This mandate is to ensure a cohesive and relevant user experience. RTCRM adamantly agrees with this approach both for general and pharmaceutical marketers. Since the practice of using a fake, unbranded display URL to drive to a branded website weakens relevancy and creates a poor and misleading user experience, it leaves RTCRM wondering why Google would permit such a disconnect. Generally, Google is known for its integrity in protecting user experience, as is apparent in its Webmaster Guidelines. These specifically ask marketers to consider the following questions: “Does this help my users? Would I do this if search engines didn’t exist?” 1917 Yahoo! Search Marketing NYC division (in-person interview) (April 4, 2009)18 Google AdWords Help Section. Advertising Policy: Editorial & Format. (2009) http://adwords.google.com/support/bin/static.py?page=guidelines.cs&topic=9271&view=all19 Google Webmaster Guidelines: Quality Guidelines. (2009) http://www.google.com/support/webmasters/bin/answer.py?answer=35769 An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 10
  12. 12. It is apparent that this unbranded display URL “exception” is in direct conflict with both the Google editorialpolicy and its Webmaster Guidelines. Why would Google permit this? Remember, lack of relevancy hurtsQuality Score and a low Quality Score can increase CPC. Could it be possible that the inherent irrelevancy ofthis fake display URL within their own relevancy-based algorithm actually makes Google additional revenue?VIII. The One-Click RuleLet us assume that a marketer chooses to deliver a truthful patient experience through the proper combinationof keywords, ad copy, and landing page. The next important component to consider is the location of anysafety information.Again, the one-click rule has been loosely interpreted to mean that the safety information can live in a link onthe landing page, rather than be fully documented on the landing page itself. This is actually two clicks, ratherthan one. To properly comply with the FDA, safety information related to the brand should be fully disclosed onthe landing page. However, if we look back at the patient pathways and mindsets that we reviewed in sectionVII, there are exceptions to evaluate.FDA Compliance for Safety Information Within One-Click• A patient who searches on a branded keyword should receive a branded website that fully discloses any safety information• A patient who searches on an unbranded keyword should receive an unbranded site. Here, the safety information is not requiredRTCRM recommends reviewing all keyword/ad copy/landing page combinations, with the patient’sexperience in mind, when considering whether the one-click rule is applicable. Let us review some examples:a) We have already established that a patient who searches on a branded keyword such as Brand should receive branded copy and be sent to a branded site. If this copy states something such as, “Brand Official Site. Learn about Benefits and Risks of Treating Osteoporosis with Brand”, a patient would expect to find this benefit and risk information immediately upon click-through. The promise a marketer needs to fulfill in this scenario is to provide the safety information upon first entry to the website, fully documented on the landing page. This, in fact, would be a best practice regardless, as again, relevancy of landing-page content helps determine a search ad’s Quality Score.b) On the flip side, if a patient receives the unbranded-keyword-to-unbranded-copy combination previously described in section VII, then they do not need to see the safety information upon entry to the website. As an example, let us say a patient searches on osteoporosis management, and receives copy that reads “Osteoporosis Management. Learn Tips and Get Support to Help Manage Your Osteoporosis.” In this scenario, risks have not been mentioned in the ad copy and the ad copy speaks directly to their search query. Generally, safety information is not required on an unbranded site to begin with, and when we consider the patient’s experience pathway in getting to this unbranded website, it is clear that they do not have an expectation of seeing any safety information.An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 11
  13. 13. Again, RTCRM believes that it is most important to evaluate the experience of a patient exposed to anymarketing material when deciding upon a search strategy.IX. Evaluating All Digital Media TacticsWhile the FDA warning letters targeted paid search specifically, other digital tactics may soon come underscrutiny as well. Organic search, contextual targeting, and banner ads all include similar elements that theFDA may oppose. These elements include ad copy, landing page content, and a patient’s exposure to safetyinformation. RTCRM believes that pharmaceutical advertisers can still engage with the majority of digitaltactics, and that it is more the creative and patient experience, than the mechanism of deployment, that shouldbe the focus of evaluation. Digital Media Risk Evaluation Risk Tactic Issue Recommendation Short ad copy requirements result Continue with unbranded search keywords and Mid Paid Search in mandatory click-through copy, but maintain best practices. Review branded to view safety information. copy on case-by-case basis with legal team. Revisit idea of including “risks” in titles Technical function of organic search leaves and descriptions to meet FDA compliance. Low Organic Search some copy out of marketer’s control. Work closely with SEO agency to implement pharmaceutical principles. Continue with content targeting, but actively Inability for proactive control of contextual monitor distribution reports. Use very generic Contextual High material that appears next to your ad may and conservative copy. Unbranded would be best Targeting create misleading experience for patient. approach. Branded not generally recommended. No Black Box. Follow similar best practices for paid search and concentrate on unbranded copy to Similar to paid search. Lack of space for unbranded website. Mid Banners safety information in banner creates need for click-through to website. Option to include multiple click tags within banners to provide safety information upon exposure. Best option for creating comprehensive and Follow best copy practices and include safety Rich Media explanatory patient experience. Plenty of information in its own panel. Use rich media as Low Banners room to include safety information upon a microsite experience to promote both branded first exposure. and unbranded content.An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 12
  14. 14. Organic SearchThere are certain intricacies that are inherent in organic search that need to be properly configured in orderfor pharmaceutical marketers to maintain compliance. While the FDA has issued no official guidance aroundorganic search, RTCRM highly recommends close vetting of titles and descriptions, which are the controllableelements of organic search. With organic search, character counts, unlike with paid search, are much longerand do allow for the inclusion of riskterminology. By reviewing and rewritingtitles and descriptions, pharmaceutical Organic Google Listingmarketers can avoid noncompliance with Linksissues, and actually improve the patientexperience moving forward.Sometimes, the search engines willpull from body copy rather than fromthe description. Marketers do not havecontrol over this, as it is an engineeringand technical function. Another elementmarketers do not always have controlover are the sporadic links that Googlesometimes displays under organic listings.If Google and the other search enginesseek to make concessions for theirpharmaceutical marketers, they shouldinclude the ability to manage theselistings as well. If one of these links always contained safety information and a marketer used FDA-complianttitles and descriptions, then the entire organic listing would provide the proper user experience based on recentFDA warnings. More information on Google organic search optimization can be found at http://www.google.com/webmasters/start/.Contextual TargetingMany marketers choose to opt in to the search engines’ content networks, which display text ads alongsidearticles of content based on the keywords or themes in that content. Some pharmaceutical marketers mayavoid content networks altogether because as a marketer you cannot control the content alongside your ad. Itmakes it very difficult to manage the patient experience when you do not know what this experience may be.While it is possible to work with the search engines to understand where your ads are appearing, due to theopaque nature of content network buys, this does not always offer full protection. When evaluating a contentnetwork strategy, marketers should consider the likelihood of an ad showing up next to misleading ornegative content. For some categories this may be less of a concern, but for Black Box drugs content targetingis not suggested. RTCRM recommends properly vetting the content network situation on a case-by-case basis.In particular, marketers may want to consider turning off branded content campaigns altogether.An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 13
  15. 15. The Evolution of Rich Media Advertising The ads have the l Banner Ads Figure 8 Rich media creates greater increases in brand metrics ad awareness (aka than standard Web ads Similar to search ad copy, there is not enough room in a standard banner to provide full disclosure of risks rich media ads. Ad and safety information. Banners can, however, have multiple click-through links, so safety information can be percentage points included in the same manner that RTCRM would like to see Google develop for search ads. Working with your for GIF/JPG ads, c increase for rich m creative and technical developers can provide solutions for including multiple links in your banner assets. Pharma, Entertai Lift in Awareness MarketNorms sho X. Safe Haven in Rich Media significantly outpe ads when it comes Rich media is really the best option for Rich Media Performance Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control likelihood to remem is especially true f pharmaceutical marketers to include safety Across Verticals such as auto, elect information alongside branded content. pharmaceuticals a Safety information and/or risk assessments are Figure 9 Rich media increases ad awareness for all industries Figure 9. fully functional in rich media units and can even Best Practice Adv have their own panel in the ad. In general, RTCRM Maximize the recommends using rich media wherever possible, Various researc because it is more engaging for the patient, Evolution’s “Th allows the marketer to deliver more content, and Online Advertis provides the agency with greater tracking and data brand awarene when the ads f measurement for analysis. prominently th ad’s animation Rich media units, with all their inherent brand quickly a functionality, increase engagement. Performing as ads often do Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control; much like a mini-website, rich media can house note - Electronics and Travel contain fewer than 30 campaigns for GIF/JPG than a constan an entire patient experience and brand exposure Tread with car in one unit. Although more expensive, they factor.” Recall Figure 10 Rich media also increases message association for usually perform better than standard banner ads, many industries necessarily a g remember a few resulting in a better ROI in the end. In fact, forget but for t a study performed by Dynamic Logic and DoubleClick in 2005 found that rich media drove higher online 10,000 times. awareness across all major verticals including pharmaceuticals.20 More recently, EyeBlaster (a major rich media Some Industries vendor) demonstrated that in a review of 35 ad campaigns totaling 340 million impressions, rich media banners Rich Media and M had a higher overall conversion rate (1.60%) than standard banners (0.70%).21 Rich media also im association for mo Additionally, because of the engaging and experiential nature of these multiple-panel units, the industry examined in the M has adopted more advanced analytics when it comes to measuring rich media’s success. All of the major rich consumer electron media vendors provide a hefty list of measurable elements. Examples of some of the more complex metrics companies found are: panel expands, percent of video viewed, and impression by Source: Dynamic Logic MarketNorms, Q2 2005; Delta equals Exposed minus Control date and hour.22 With better measurement message associat shown in Figure 1 comes more advanced ROI modeling – something that all marketers, pharmaceuticals included, can benefit from implementing. 920 DoubleClick. The Evolution of Rich Media Advertising: Current Market Trends, Success Metrics and Best Practices. (Sept. 2005)21 EyeBlaster. Path to Conversion: Getting the Right Mix. (2009) http://www.eyeblaster.com/Data/Uploads/ResourceLibrary/Path%20to%20Conversion_2009.pdf22 EyeWonder. Technologies: AdWonder Reporting Platform. Ad Tracking and Reporting. http://www.eyewonder.com/technologies_adtracking.php An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 14
  16. 16. XI. ConclusionIn the end, each pharmaceutical company will need to work with its legal team to make any final decisionsregarding digital tactics.While RTCRM believes that the pharmaceutical industry can safely continue marketing through paid search,the fears that have arisen as a result of the FDA warning letters are understandable. Where concern is toogreat or the patient experience too risky, rich media offers the safest haven for comprehensive alignment ofa pharmaceutical brand and its safety information.Where marketers are willing to optimize their paid search campaigns in compliance with the FDA, RTCRMsuggests following the basic guidelines outlined in this discussion. In the end, relevancy and complianceare the two most important factors to consider and, as discussed, can be managed in a way that does notdistract from the patient’s experience. Both branded and unbranded paid search can be implemented ina conservative yet search engine–friendly way, allowing pharmaceutical marketers to continue to reachprospective patients with highly relevant ads.And as the pharmaceutical companies continue to see value in search marketing and are willing to work extrahard to fit compliant terminology within 95 characters of ad copy, Google too should consider working toengineer a functionality that can include this safety information in the first exposure.RTC Relationship Marketing Headquarters in Washington, DC1055 Thomas Jefferson Street, NWSuite 200Washington, DC 20007202.625.2111An Eye on Google: Re-engaging with digital marketing in response to recent FDA warnings 15

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