Jun 30, 2010
As many of you have noticed lately, every time you search for a pharmaceutical product by brand name in Google, virtually all of the #1 organic ranks link to an associated NIH site with a “pill” icon designating the site is an NIH site (hello…anyone remember the idea at the FDA hearings last year about an icon denoting an FDA-safe (read between the lines ‘endorsed’) site?
During the FDA hearings, the government was adamant about ensuring consumers get the right information about drug products, with accurate safety/risk information, and that health literacy is a priority so that our consumers have all of the information they need to educate themselves about drug products and therapies so they can have productive conversations with their doctors and make informed decisions.
There are several issues I have with the present Google/NIH deal:
1. Not all drug product searches yield these results (type in Symbyax or Adcirca into Google and an NIH site is nowhere to be found). The bots and spiders may catch up, but for now, many products are missing.
2. The NIH is promoting itself and its (‘self-proclaimed’) authority on the accuracy of drug information through a deliberate business deal with Google.
3. Much of the NIH information is outdated and inaccurate. I ran searches on a few of our clients’ products and one of the NIH links served up outdated information from 2005 (as the most recent, which is laughable). Since 2005 the product has gone through label expansions, updated safety information, etc. None of which is included in the NIH 2005 posting.
So what’s my point?
My point is that the NIH is now acting as a marketer. It has formed a relationship with Google to get into the healthcare marketing game. Plain and simple.
If this were a pharma promotion, the NIH would be making claims that their information is more accurate--and better--than any brand.com site. They are making an implied superiority claim.
Yet, there is no head-to-head. Not controlled trials, no study design to reassure consumers that the NIH information is superior to the information on the brand.com websites. I’d even go so far as to argue that NIH sites are outdated and potentially open up the risk of harming consumers. What’s even worse is this feels like a poor attempt to grab market share from WebMD and other consumer medical resource communities that quite honestly have better marketing models and tighter controls on the quality and accuracy of their information.
When scrutinized under the present FDA regulatory lens…the NIH is in violation of pharmaceutical promotional guidelines. Not only is much of their information wrong or outdated, placing a “seal of approval” icon (the ugly pill) misrepresents to consumers that this is the most accurate, up to date information about drug products. This is dead wrong, and quite frankly (depending on the NIH content) false advertising/information.
Call me crazy…but I’d go so far as to say the NIH should receive an FDA warning letter for making claims and misrepresenting information with no ‘fair balance’, not to mention they are not providing proper indication and risk information within ‘space limited advertising’ (sorry, I had to take that last shot).
I would WELCOME comments on this blog post and like to hear your thoughts. If I receive enough responses, with opinions and data that have merit, I’ll commit to you to send a letter with supporting data down to FDA so that we can assist the FDA in properly compiling social media guidelines that ensure the government lives by the same rules we all have to.
I welcome your thoughts and comments.