Two decisions, in particular, bring pharma paid search ads in alignment with advertisers in other categories. The first is the elimination of the black box ad unit, which made special accommodations for drugs that need to carry an FDA-mandated Black Box Warning to disclose certain side effects. The ad unit will go away entirely within a month, which will leave some pharma advertisers scrambling for a new approach.
While some advertisers will no doubt develop workarounds that involve expanded site links or some other method of ensuring Black Box information is carried with branded search ads, those workarounds aren’t ideal and will certainly require scrambling with legal teams to assess those alternatives. In the meantime, Google has communicated the discontinuation of this ad type to the FDA in order to keep them in the loop.
The intricacies of how search works is sometimes lost on the FDA, which has – on occasion – issued guidance for marketers that seems to be at odds with earlier requirements for search ads.
This does seem to be an interesting signal from Google, given that they’ve presented ad formats to the FDA over the years in order to accelerate search ad investments by pharma marketers. While Google may have platform-related reasons for bringing pharma into alignment with search advertisers in other industries, it seems to say that the exceptions made for pharma marketers in the past might not continue into the future.
Another recent decision concerns the use of masking URLs, which will disappear in January of next year. Pharma advertisers often use masking URLs in unbranded campaigns, for which restrictions are looser than they are for branded campaigns. The use of masking URLs keeps a brand from being mentioned in association with a condition, which would violate FDA guidelines unless the ad were to also carry all the required accompanying disclosures. With character limits being what they are, this obviously presents a problem.
While marketers and their agencies have time to plan for this second change, the departure of masking URLs is another signal to pharma marketers that they need to plan workarounds because Google will be making fewer accommodations for their unique business requirements. Unlike the situation with Black Box Ads, though, the retirement of masking URLs leaves pharma marketers with questionable alternatives that might not pass legal scrutiny.
In the absence of Google continuing to make special accommodations, it would be nice to see the FDA make some proactive decisions to issue guidance, in order to eliminate uncertainty. While agencies and their clients will have plans for going forward, these new developments may have a chilling effect on search investments if the Legal Powers That Be believe the risk to outweigh the benefit of working around the changes.
Oliver Nelson currently leads digital media strategy across several healthcare, pharmaceutical and OTC categories with a focus on digital display, social media, search engine marketing (SEM) and search engine optimization (SEO.) While Mr. Nelson’s passion lies with SEO, he has over ten years’ experience in retail and corporate marketing, sales and advertising and has managed both online and offline media campaigns for several private and public organizations. Mr. Nelson graduated from the Boston College Carroll School of Management with a Bachelors of Science in marketing. In addition, Mr. Nelson is a top graduate of the United States Army Intelligence School and a veteran of Operation Enduring Freedom.