According to FDA, the new ‘Bad Ad’ program aims to train healthcare professionals “to recognize misleading prescription drug promotion and provide them with an easy way to report this activity to the agency.” It encourages them to report violations directly to DDMAC via phone or email (with the option to do this anonymously). Who thought this was a good idea?

Is the FDA actually going to ‘train’ physicians to be their ‘promotional police’? We all know how much experience and training physicians have in the area of marketing and sales promotion, and now they’re going to assess if our communications - which have already gone through extensive marketing, medical, legal and regulatory review - are appropriate.

And the name - the “Bad Ad” Program – what happened to ‘innocent until proven guilty’? The pharmaceutical industry is doing so much these days to live within very strict federal/state guidelines, increase disease awareness to improve healthcare and interact with consumers via social media in an ‘undefined’ regulatory environment, and this is the ‘thanks’ we get? Maybe next time the FDA feels overworked and understaffed they can create a “Fair Balance” Program and practice what they preach.

So what’s your take on the FDA’s ‘Bad Ad’ Program?’ Share your thoughts in the comments below.

Posted by Jay Bolling (@RoskaHC), President and CEO at Roska Healthcare Advertising.

On Monday, Center for Digital Democracy -- a not-for-profit consumer advocacy group -- sent a letter to FDA Commissioner Margaret Hamburg urging the agency to consider certain restrictions on how drug and medical device companies use websites and social media platforms to market their products, Modern Healthcare reports (note: you will have to register to obtain the report).

As FDA works to develop rules on the online marketing of medical products, CDD recommended that the agency consider:

• Prohibiting drug and medical device companies from using space-limited tools -- such as text messages and Twitter -- to market products;
• Preventing companies from using online behavior-tracking technology to gather data on consumers; and
• Requiring drug and device firms to disclose their relationships with health information portals.

With the exception of bullet number three, these recommendations do not take into account the realities of how we communicate today and the behaviors and needs of consumers.

Now more than ever, consumers are skimmers, moving quickly to scan through volumes of information – trying to find meaningful information in minimal time.

Wouldn’t we want to figure out a way to fulfill that need through microblogs like Twitter, in an FDA-compliant way? Might consumers actually appreciate our assistance in gathering information to attempt to serve up more relevant content and message that better meet their needs?

I’d welcome your thoughts on this post, as I think the CDD is off target in this recommendation.

What are your thoughts?