FDA Studies Corrective Ads
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?Corrective ads are a serious issue for drug companies.? |
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The FDA will be doing a study on the effect of corrective advertising on consumer perception of brands. The FDA rarely uses the penalty but has it in its power to force drug companies to runs ads telling consumers that it made false statements.
As far as I know, there are no studies that show whether corrective advertising works. Does it do what was intended by FDA? Do consumers understand what was false and does the new ad convey the truth about benefits? Do consumers who see it view the brand differently than those who only saw the original ad?
As with most FDA studies the results will take some time. Usually, it takes government time, that is, much longer than a private company would take. However long it takes, it will be an interesting addition to DTC studies. These results may provide FDA an opportunity to issue new guidance on how to do corrective ads.
The last corrective ads were ordered for the contraceptive Yaz in 2009. Since most ads pre-clear the most egregious statements are weeded out. Most television ad warnings are for lack of adequate fair balance, or for distracting visuals during risk statements. Rarely do we see television ads that run unsupported benefits. These sometimes make it to drug rep detail aids but almost never in television.
Corrective ads are a serious issue for drug companies. No CEO wants the negative publicity from the FDA ordering corrective ads. The media likes to run this type of story about bad drug companies lying to consumers. Then of course there is the media spending required to run the new ads. FDA will generally ask the company to run the same level of media that it ran with the original ad. Then there is Congress always looking to hold a hearing or two on the evils of DTC. A CEO?s worst nightmare is to be grilled by Henry Waxman on why the company lied to the American public.
Most corrective ads will never say the company lied. They will use soft language like ?what we told you before was not quite accurate?, or ?we wanted to correct a misstatement that may have given you a false impression.? FDA may find that consumers actually have a better impression of the brand after corrective ads because consumers like a company that can admit they screwed up.
I support the use of the corrective ad penalty when it is warranted. The fact that it is rarely used shows that FDA is judicious in ordering it. Companies that do not pre-clear are making a mistake. I have found FDA reviewers generally fair and timely in reviewing television ads. I hope this new study will add to the body of DTC knowledge and will be interested in what they learn.
Bob Ehrlich, Chairman
DTC Perspectives, Inc.
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