Future Challenges and Opportunities in Online Prescription Drug Promotion Research Comment on "Trouble Spots in Online Direct-to-Consumer Prescription Drug Promotion: A Content Analysis of FDA Warning Letters"

Abstract

Despite increased availability of online promotional tools for prescription drug marketers, evidence on online prescription drug promotion is far from settled or conclusive. We highlight ways in which online prescription drug promotion is similar to conventional broadcast and print advertising and ways in which it differs. We also highlight five key areas for future research: branded drug website influence on consumer knowledge and behavior, interactive features on branded drug websites, mobile viewing of branded websites and mobile advertisements, online promotion and non-US audiences, and social media and medication decisions. A s Kim 1 notes, the emergence of online prescription drug promotion warrants research, both to inform regulation in countries that allow direct-to-consumer (DTC) promotion and to understand consumer behavior around the world. Although healthcare providers continue to be highly trusted sources of health information, consumers often first consult Internet-based sources to answer questions about health conditions or medications.2,3 At the same time, pharmaceutical companies are increasingly using online promotional tools, such as branded drug websites, online videos (eg, YouTube), and social media (eg, Facebook, Twitter, online forums, and chat rooms), to provide information about prescription drugs.4-8 Yet these online tools-as demonstrated by Kim and others [9][10][11] -often fail to present balanced information about prescription drug benefits and risks. Despite the availability of online promotional tools, however, the evidence on online prescription drug promotion is far from conclusive. Kim's study helps to address the need for new research; her overview of a decade of warning letters issued by the U.S. Food and Drug Administration (FDA) highlights some important observations. She notes that online promotion, like conventional broadcast and print advertising, harbors numerous instances of inaccurate description of drug benefits and risks. Unlike conventional broadcast advertising, however, online promotion can pose unique space constraints (such as character and space limits in Internet search engine results) that can make benefit and risk description challenging. Moreover, social media applications beg new questions about the influence of interpersonal communication online. From a regulatory perspective, we should examine additional dimensions in FDA warnings beyond Kim's current analysis. Specifically, future research should compare online DTC warnings against conventional broadcast and print ad warnings, should distinguish between notices of violation and more serious warning letters, and should compare the volume of FDA warnings against the prevalence of each DTC activity. These assessments would help to identify how online DTC violations compare to traditional DTC violations and whether the high volume of warnings for branded drug websites is because such sites are more prevalent than other online DTC activities. From a decision science perspective, we need to expand onl...

Advertising of Over-the-Counter Codeine-Containing Medicines in the EU: Differences in the Regulation of Advertising Between Member States

“…Additionally, online promotional advertising of prescription medicines accessible globally presents additional challenges for national regulatory agencies not permitting direct-to-consumer advertising of medicines either prescription or OTC. While traditional print and broadcast media can be controlled to a certain extent, online promotions have the ability to cross national boundaries through various media platforms to countries when it is not legal (16).…”

“…Direct-to-consumer advertising of prescription drugs is illegal in the EU. However, it is suggested that consumers often access online content and view branded drug websites in the United States and New Zealand where direct-to-consumer advertising of prescription drugs is legal (16).…”

How Affiliation Disclosure and Control Over User-Generated Comments Affects Consumer Health Knowledge and Behavior: A Randomized Controlled Experiment of Pharmaceutical Direct-to-Consumer Advertising on Social Media

“…Due to its unparalleled scope and a complete lack of rigid law enforcement, online DTCA contributes to the characterization of Internet activity as being akin to the “Wild West” [ 4 ]. Overall, there is a critical need for more research that examines how online DTCA affects consumer health knowledge and decision making [ 5 ].…”

“…This study examines two serious concerns about online DTCA that researchers and health professionals view as essential to address [ 5 - 8 ]. The first major concern is that pharmaceutical companies might market their drugs on social media indirectly through seemingly neutral third-party sources that are, in reality, controlled or influenced by the pharmaceutical companies [ 5 - 7 , 9 ]. We examine the ramifications of such practices on social media for both individual commenters and for organizations that post drug information.…”

“…The emergence of social media and other interactive platforms has only exacerbated concerns related to DTCA leading prominent scholars and health professionals to wonder “...whether regulatory responses by FDA are responsive and adaptive enough to address the inherent challenges faced by a universe of digital and Internet-based forms of DTCA” (p 271 [ 12 ]). Specifically, researchers and health professionals are extremely concerned that companies will market their drugs online in ways that (1) obscure the role companies play in producing drug information, and (2) strategically control user-generated contributions to promote a favorable, one-sided view of a company and its products [ 5 , 8 , 12 ]. A recent content analysis clearly documents how prominently pharmaceutical companies are using Facebook, YouTube, and Twitter for promotional activities [ 3 ].…”