Digital Direct-to-Consumer Advertising: A Perfect Storm of Rapid Evolution and Stagnant Regulation Comment on "Trouble Spots in Online Direct-to-Consumer Prescription Drug Promotion: A Content Analysis of FDA Warning Letters"

Abstract

The adoption and use of digital forms of direct-to-consumer advertising (also known as "eDTCA") is on the rise. At the same time, the universe of eDTCA is expanding, as technology on Internet-based platforms continues to evolve, from static websites, to social media, and nearly ubiquitous use of mobile devices. However, little is known about how this unique form of pharmaceutical marketing impacts consumer behavior, public health, and overall healthcare utilization. The study by Kim analyzing US Food and Drug Administration (FDA) notices of violations (NOVs) and warning letters regarding online promotional activities takes us in the right direction, but study results raise as many questions as it does answers. Chief among these are unanswered concerns about the unique regulatory challenges posed by the "disruptive" qualities of eDTCA, and whether regulators have sufficient resources and oversight powers to proactively address potential violations. Further, the globalization of eDTCA via borderless Internet-based technologies raises larger concerns about the potential global impact of this form of health marketing unique to only the United States and New Zealand. Collectively, these challenges make it unlikely that regulatory science will be able to keep apace with the continued rapid evolution of eDTCA unless more creative policy solutions are explored.

Are direct messages (texts and emails) from wagering operators associated with betting intention and behavior? An ecological momentary assessment study

“…Research into US pharmaceutical advertising has noted the difficulty of regulating direct marketing (Gibson, 2014; Henney, 2000; Mackey, 2016; Taylor, Franke, & Maynard, 2000). Gibson (2014) concluded that third party oversight and industry self-regulation are important in regulating direct marketing, although gambling industry self-regulation has been criticized (Selin, 2016).…”

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

“…Past research suggests companies have minimized or obscured such disclosures [ 32 ]. The bigger challenge, however, is whether it is feasible to regulate how pharmaceutical companies control information about their products across new media platforms that they might only indirectly influence or control [ 7 , 12 ]. Obviously pharmaceutical companies should not be expected to police the entire Internet.…”

“…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 ].…”

From The Printing Press to Telemedicine: Communication Technology and Its Impact on Health

“…In 2016, pharmaceutical companies spent over $6.4 billion to advertise directly to U.S. consumers, using practices that could easily mislead the consumer about the efficacy of their medications and their side effects, or prompt consumers to request medication that is unnecessary. In 2015, the American Medical Association voted to support a ban on direct-to-consumer advertising (Mackey, 2016). The original intent of the FDA's guidelines that allow direct-to-consumer pharmaceutical advertising was to encourage consumers to seek additional information online and elsewhere (Chesnes & Jin, 2016;Horovitz & Appleby, 2017).…”