The FDA Commissioner’s Flawed View of Drug Ads
This weekend the NYT ran an opinion piece by FDA commissioner Dr. Marty Makary attacking direct to consumer advertising of pharmaceuticals. I teach healthcare marketing at Northwestern University’s Kellogg School of Management and can’t resist responding.
In his article, Makary presents the usual attacks on pharma ads: they promise too much, disclose too little and lead to overuse of expensive medications.
He writes that in most drug ads, “the most common message seems to be that a drug will instantly transform you to be singing and dancing endlessly.”
This ridiculous generalization about drug ads an insult to anyone working in healthcare communications. It is disappointing when a senior healthcare regulator presents absurd statements as fact.
Dr. Makary then notes that the FDA will be pursuing companies for advertising efforts and making dramatic changes in the regulatory landscape. If allowed, the actions will largely eliminate healthcare advertising to patients.
Makary’s attack on pharma ads is flawed in many ways. Let me review just a few.
Informing Patients
There is general agreement in the U.S. that patients should be involved in their healthcare decisions. The ideas of shared decision-making and informed consent are at the heart of this: patients should have a voice in their care and be active participants.
Healthcare advertising is one source of information. When people see advertisements about different diseases and medications, they learn about available options. People are skeptical of advertising, but patients might ask questions and learn more.
Studies show that informed patients are better patients. When people understand their condition and prescribed medication, they are more likely to actually fill the prescription, take it and stick with it. In one study, patients who asked for a specific medication received better care overall, though usually not the requested medication.
Dr. Makary seems to think patients are best left in the dark when it comes to healthcare. He writes, “As a physician, I’ve had patients walk into my office to ask about medicines they saw advertised,” suggesting this was a terrible situation.
Why is letting people know about medications a bad thing? Aren’t patient questions good?
The Role of Physicians
Individual patients can’t access medications on their own; they need a health care provider to provide a prescription.
This means that the worst thing that might happen from a pharma ad is that a patient will ask a doctor for a particular drug. It is then up to the physician to determine if the drug is appropriate and explain it to the patient.
Dr. Makary believes that patient questions distort medicine. He writes, “For far too long, these ads have distorted the physician-patient relationship and have created increased demand for medications regardless of whether they are appropriate for the patient.”
Patient engagement leads to better healthcare outcomes, not worse.
In reality, most doctors don’t make medical decisions based on patient requests; they are trained to identify diseases and provide the best possible care.
If Dr. Makary really believes that doctors are blindly giving patients prescriptions for medicines they don’t need, the problem is with the doctors, not the companies.
Regulated Content
Ads from pharmaceutical and medical device firms are tightly regulated; there are clear rules around what companies can say, and what they must disclose. For example, companies can only make claims that are grounded in rigorous, scientific studies. The size of the type, the choice of talent and the visual composition in a piece of advertising are all restricted.
Dr. Makary notes that some advertising doesn’t comply with existing regulations, such as the Super Bowl spot from Hims & Hers that flagrantly violated the rules. The FDA is right to evaluate healthcare advertising and ensure that spots that don’t follow the regulations are taken off the air. The lack of warning letters in recent years suggests that some step-up in enforcement is warranted.
Compared to regulated drug ads, most healthcare content on the internet isn’t evaluated at all. An individual can post pretty much whatever they want about different drugs and therapies.
If an influencer wants to sing the benefits of using a drug in a totally inappropriate way, there are no restrictions. Pharmaceutical firms are absolutely blocked from doing this, but not individuals.
Alternatively, someone can attack a therapy as dangerous even if there is no data supporting the claim. If a creator wants to encourage people to lay on the kitchen table for 20 minutes each day while taking Advil to improve their inner spirit, they are free to do so.
If the FDA is successful at blocking healthcare firms from communicating information about their products to patients – content that is scrutinized, accurate and fair balanced – the result will be a world where the only health information available to individuals is completely unregulated.
Healthcare advertising isn’t a problem; it is way for patients to gather information. Imposing restrictions that will eliminate it will leave the U.S. healthcare system less well-off.
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