Helping Clients Navigate Compliant Communications for FDA-regulated Products

Helping Clients Navigate Compliant Communications for FDA-regulated Products IMAGE_EDVANITY URLS: Google Paid Search Engine Marketing (SEM) Changes
• Redirecting ad changes effective January 12, 2016
• Prohibiting ads where vanity URLs are utilized and dramatically different from the destination URL

Google has announced significant changes in their paid search engine advertising policies with regard to pharmaceutical products. The change that we are addressing here deals with vanity URLs, and their respective redirecting ads, that will take place in January 2016. The bottom line is that Google will no longer allow vanity URLs in an effort to provide consumers with more “clarity and transparency.”

Google has a long-standing policy prohibiting any ads where the destination URL differs dramatically from the display URL. Please note, this prohibition is not exclusively for pharmaceutical products—it has been Google’s practice across the board. Up until now, the pharmaceutical industry had been the exception to the rule. The reason for the exception was because in many cases, information seekers will not know the name of a drug, but will understand and know the symptoms/disease state information.

FDA background information
Previously, the FDA never objected to marketers utilizing vanity URLs and/or redirecting ads. These URLs/ads typically do not directly promote the name of a prescription product. Instead they lend themselves more to a disease state or descriptive nature, and then redirect users to another location or URL where they will see branded information specific to the prescription drug and/or disease state. Vanity URLs/redirecting ads are not exclusive to online SEM use, and are also used in print ads, television commercials, billboards, postcards, and more.
In March 2009, the FDA sent out 14 violation letters regarding search engine marketing practices of 48 brands. Thirteen of those violations referred to SEM ads running on Google. The FDA noted four types of violations in 2009:

  1. Omission of risk information, failure to meet requirements of 21 CRF 202.1(e)(5)(ii)
  2. Inadequate communication of indication
  3. Overstatement of efficacy
  4. Failure to use the required established name

Google’s reaction—what exactly is Google implementing?
Beginning in January 2016, Google will not permit pharmaceutical advertisers to have vanity URLs (such as “TreatmentforConditionX.com”) that redirect users to a BrandName.com website.

Pharmaceutical marketers will have the following options for vanity URLs:
Option 1

ConditionSymptomsGoogle-01

Sample ad showing company name as URL

Option 2
They can add “.com” to the company name.

ConditionSymptomsGoogle-02

Sample ad showing company name plus .com as URL

Option 3a (for prescription drugs, biologics, and vaccines)
They can display the phrase “Prescription treatment website” as the display URL.

ConditionSymptomsGoogle-03

Sample ad showing prescription treatment display URL

Option 3b (for medical devices)
They can display the phrase “Prescription device website” as the display URL.

ConditionSymptomsGoogle-04

Sample ad showing device display URL

All of these ads will be able to drive to pages on the brand.com or brandhcp.com website.

At the present time, this change has been instituted by Google only, and doesn’t lend itself to print, television, or other advertising mediums.

What does this mean for our clients?
Review and reassessment of live and proposed Google SEM campaigns where clients utilize vanity URLs need to be completed as soon as possible. New campaigns need to take these new rules into consideration during the tactical planning phase. Funds can be shifted to Yahoo and Bing, however there is the possibility that they may also follow suit.

Google has indicated a willingness to work with pharmaceutical clients to minimize potential negative impact to paid search campaign performance. Testing of the new formats will determine which type of units work best with various campaigns.

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