Jun 30, 2010

FDA, Government and NIH Seek to Influence Social Media Guidelines and Space Limited Ads

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?

Wendy Blackburn recently posted a nice POV on her blog about this issue.

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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 Much of the NIH information is outdated and inaccurate. I ran searches on a few of our clients’ products and one of the NIH links served up outdated information from 2005 (as the most recent, which is laughable).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  I’d even go so far as to argue that NIH sites are outdated and potentially open up the risk of harming consumers.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.

11 comments:

  1. I agree with you completely! This is shocking

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  2. Thank you "Anonymous". I'm receiving similar DMs on the twitter handle @RoskaDigital

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  3. Before we flame the NIH, has anyone actually confirmed that the NIH proactively pursued this relationship? Might it be that Google asked for permission to use the excerpt. They don't need permission to link to their site. Besides, the NIH doesn't even own the copyright on the excerpt or full information. The The American Society of Health-System Pharmacists owns it and maintains it. I'm fairly sure that this isn't some powergrab or attempt to "market itself" by the NIH. Why would they want to do that?

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  4. Does anyone actually believe Google is doing this to improve the accuracy of health information?? If so, have you been to the NIH website?

    Google stands to profit most from this deal. We all know that pharma cos. have pulled back their advertising dollars. With this threat to product.com traffic, I think the perception from pharma will be that they need to open up their wallets to make up for lost traffic.

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  5. Thanks for the thoughts Jonathan and Arly.

    To Arly's point...I agree this is about revenue for Google. Assuming the stats from Wendy are close, there is a significant drop in number of clicks for sites in the #2 position. What other way does pharma have to get their clicks back than to go through paid search? Google is forcing the algorithm. No amount of content, digital asset optimization or any other technique will wrench the NIH out of the first position.

    To Jonathan's point, I doubt anyone will ever find a document that has been published about what type of arrangements were made. However (and I might be cynical in this view) this is good PR for the NIH and driving traffic to their site. And, it is good for Google PR in building their Google Health offerings.

    Setting even this aside for the moment, the real question should be "Is this helping consumers find the most accurate, unbiased drug and disease information?"

    I would argue "no."

    I'm receiving emails from brand managers crying "foul" that the information about their products on the NIH site are outdated and not completely accurate.

    How is this helping consumers and health literacy?

    To be completely fair, there are a decent number of NIH pages that are accurate and do a good job of providing drug and disease information.

    However, if the standard is now that NIH sites rule above all others, then Google and the NIH owe it to consumers to ensure measures are put in place so all information is accurate and kept absolutely 100% up to date whenever labeling changes.

    I'd offer one closing thought on the above...even if Google and NIH can't police the content, shouldn't they at least add a beneficial disclaimer for the consumer to the effect of "Information on this site may not be 100% accurate or include all product information. Please consult your doctor"?

    In the absence of the above, the consumer is mislead that this is accurate, up to date information, when in many cases it is not.

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  6. Very interesting topic Kurt!

    First re: your #2 point--- The only reason I believe the NIH has a “deal” with Google relates to the custom links below the individual organic search result (ie:” How to take - Side effects - Precautions - Dietary Instructions - Missed a dose”)

    Without full knowledge of what “deal” exists- if any--here’s my assumption/take on your POV. (caveat: Hypothetical situations based on my best guess assumptions from sample searches I just did, search results and how the info is served up on the NIH site.)

    Are they acting as marketers to promote the most relevant content to the searching masses. YES

    Are they claiming superiority for certain drugs? NO

    Is Google the one we should be talking about? YES

    I smell Google all over this. They likely went to the NIH with a business model “for leveraging pharma” b/c of their site's richness in content netting in top organic search results.

    IF (and I say IF b/c I don’t know) the NIH then went and established their own business model with pharma companies to submit relevant content on certain drugs/agents (and keep them current on their site) that is smart. They are a 3rd party government regulated association that wants/needs to provide relevant, medically relevant content. I doubt they have the staff to keep up with this type of research so they likely opened it up to pharma to submit their own updates for ease and validity of medical information.

    If that is the case--- as long as what is “submitted” to the NIH from Pharma companies are heavily regulated/reviewed by NIH internal medial staff/editors and remains un biased--- I feel they are only doing the world a service by offering credible and relevant information on drugs/medical information that people search for.

    And if you were pharma- think about the opportunity here. Greater reach of product info by leveraging credible 3rd party online destinations. How much more exposure your “credible and 100% relevant” information would be to consumer--- knowing it shows up in the top-10 search ranking and is 60% more likely to be clicked on?

    For the drugs that are outdated (per your 2005 data comment) yes there is a disservice to information seeking people. I just think it’s really hard/unrealistic to keep up to date with every drug out there 24/7. I think the NIH you would need MD/editors round the clock to do that. 100s of them. Think how long it takes *just* to get a label updated and out to the public. Just saying…

    Anyway- IF this is the case, I would recommend a disclaimer on behalf of the NIH in its connection to Pharma. Transparency is everything.

    Also- some sort of disclaimer a/b the timely update of information not always being 100% and to check with the pharma medical affairs group for further info, etc…

    Again- just stating all hypothetical situations based on my best guess assumptions on what I see in search results and how the info is search up on the NIH site.

    Will be watching to see if any info is released re: deals with NIH/Pharma.

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  7. Very interesting topic Kurt!

    First re: your #2 point--- The only reason I believe the NIH has a “deal” with Google relates to the custom links below the individual organic search result (ie:” How to take - Side effects - Precautions - Dietary Instructions - Missed a dose”)

    Without full knowledge of what “deal” exists- if any--here’s my assumption/take on your POV. (caveat: Hypothetical situations based on my best guess assumptions from sample searches I just did, search results and how the info is served up on the NIH site.)

    Are they acting as marketers to promote the most relevant content to the searching masses. YES

    Are they claiming superiority for certain drugs? NO

    Is Google the one we should be talking about? YES

    I smell Google all over this. They likely went to the NIH with a business model “for leveraging pharma” b/c of their site's richness in content netting in top organic search results.

    IF (and I say IF b/c I don’t know) the NIH then went and established their own business model with pharma companies to submit relevant content on certain drugs/agents (and keep them current on their site) that is smart. They are a 3rd party government regulated association that wants/needs to provide relevant, medically relevant content. I doubt they have the staff to keep up with this type of research so they likely opened it up to pharma to submit their own updates for ease and validity of medical information.

    If that is the case--- as long as what is “submitted” to the NIH from Pharma companies are heavily regulated/reviewed by NIH internal medial staff/editors and remains un biased--- I feel they are only doing the world a service by offering credible and relevant information on drugs/medical information that people search for.

    And if you were pharma- think about the opportunity here. Greater reach of product info by leveraging credible 3rd party online destinations. How much more exposure your “credible and 100% relevant” information would be to consumer--- knowing it shows up in the top-10 search ranking and is 60% more likely to be clicked on?

    For the drugs that are outdated (per your 2005 data comment) yes there is a disservice to information seeking people. I just think it’s really hard/unrealistic to keep up to date with every drug out there 24/7. I think the NIH you would need MD/editors round the clock to do that. 100s of them. Think how long it takes *just* to get a label updated and out to the public. Just saying…

    Anyway- IF this is the case, I would recommend a disclaimer on behalf of the NIH in its connection to Pharma. Transparency is everything.

    Also- some sort of disclaimer a/b the timely update of information not always being 100% and to check with the pharma medical affairs group for further info, etc…

    Again- just stating all hypothetical situations based on my best guess assumptions on what I see in search results and how the info is search up on the NIH site.

    Will be watching to see if any info is released re: deals with NIH/Pharma.

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  8. Thanks Jess. I think this is one of the best comments received so far. What I like most is the idea of having NIH and pharma working together to ensure accuracy of information and that it is current. If they can achieve that goal, then the service truly does benefit the patients as intended.

    Thanks so much for the comments.

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  9. Kurt, great post. I have no idea about "deal or no deal" with NIH Google etc. But, I think you touch on a much bigger issue of who should judge what's good, best, of most interest to consumers. The reality is, of course, Dr. Google plays this role. But even their classic sites-with-more-links-rank-higher methodology means Wikipedia entries always rank high, although no physician review, passive text, written at high grade levels. Ideally sites that were current, created with some clinical credibility, and IMHO interactive would rank higher than those that aren't. Once again, while many people are acting like e-patients, are they really trained to discern the good from the bad and what or who is behind the source.

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  10. Kevin -- thanks for the insight and opinion. I think you make some great points on health literacy and a consumer's ability to discern good from bad (or inability to do so).

    Anything we, Dr. Google, NIH or pharma, through brand.com can do to get together and put the best solution forward, would most certainly be well received by all parties.

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  11. This comment has been removed by a blog administrator.

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