Helping Clients Navigate Compliant Communications for FDA-regulated Products

Helping Clients Navigate Compliant Communications for FDA-regulated Products IMAGE_EDVANITY URLS: Google Paid Search Engine Marketing (SEM) Changes
• Redirecting ad changes effective January 12, 2016
• Prohibiting ads where vanity URLs are utilized and dramatically different from the destination URL

Google has announced significant changes in their paid search engine advertising policies with regard to pharmaceutical products. The change that we are addressing here deals with vanity URLs, and their respective redirecting ads, that will take place in January 2016. The bottom line is that Google will no longer allow vanity URLs in an effort to provide consumers with more “clarity and transparency.”

Google has a long-standing policy prohibiting any ads where the destination URL differs dramatically from the display URL. Please note, this prohibition is not exclusively for pharmaceutical products—it has been Google’s practice across the board. Up until now, the pharmaceutical industry had been the exception to the rule. The reason for the exception was because in many cases, information seekers will not know the name of a drug, but will understand and know the symptoms/disease state information.

FDA background information
Previously, the FDA never objected to marketers utilizing vanity URLs and/or redirecting ads. These URLs/ads typically do not directly promote the name of a prescription product. Instead they lend themselves more to a disease state or descriptive nature, and then redirect users to another location or URL where they will see branded information specific to the prescription drug and/or disease state. Vanity URLs/redirecting ads are not exclusive to online SEM use, and are also used in print ads, television commercials, billboards, postcards, and more.
In March 2009, the FDA sent out 14 violation letters regarding search engine marketing practices of 48 brands. Thirteen of those violations referred to SEM ads running on Google. The FDA noted four types of violations in 2009:

  1. Omission of risk information, failure to meet requirements of 21 CRF 202.1(e)(5)(ii)
  2. Inadequate communication of indication
  3. Overstatement of efficacy
  4. Failure to use the required established name

Google’s reaction—what exactly is Google implementing?
Beginning in January 2016, Google will not permit pharmaceutical advertisers to have vanity URLs (such as “”) that redirect users to a website.

Pharmaceutical marketers will have the following options for vanity URLs:
Option 1


Sample ad showing company name as URL

Option 2
They can add “.com” to the company name.


Sample ad showing company name plus .com as URL

Option 3a (for prescription drugs, biologics, and vaccines)
They can display the phrase “Prescription treatment website” as the display URL.


Sample ad showing prescription treatment display URL

Option 3b (for medical devices)
They can display the phrase “Prescription device website” as the display URL.


Sample ad showing device display URL

All of these ads will be able to drive to pages on the or website.

At the present time, this change has been instituted by Google only, and doesn’t lend itself to print, television, or other advertising mediums.

What does this mean for our clients?
Review and reassessment of live and proposed Google SEM campaigns where clients utilize vanity URLs need to be completed as soon as possible. New campaigns need to take these new rules into consideration during the tactical planning phase. Funds can be shifted to Yahoo and Bing, however there is the possibility that they may also follow suit.

Google has indicated a willingness to work with pharmaceutical clients to minimize potential negative impact to paid search campaign performance. Testing of the new formats will determine which type of units work best with various campaigns.

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The Age of Wearable Health Technology Is Upon Us

5240666It used to be that technology that conforms to the human body and seamlessly integrates into your environment was stuff of science fiction movies. But if we’ve learned anything over the past 10 years, we know that science fiction is rapidly become science-fact. If you wanted to see what the near future held, all you had to do was tune in to the numerous news feeds covering the 2014 Consumer Electronics Show (CES) January 7–10. If there was one trend that seemed to be on every manufacturer’s mind, it was wearable health technology. In fact, CES expanded exhibitor floor space by 40% just for digital health and fitness exhibitors, many of whom were showcasing wearable personal devices.

CES is known as an event where electronics manufacturers like Samsung preview the mainstream consumer electronics that will drive the holiday shopping season. It’s the place where the industry goes to see everything from the latest web-connected refrigerators to the latest mobile chips. And the news from this past CES convention was no different. In the past, consumer electronics companies have been focused on portable, mobile technologies. With the mainstream adoption of smartphones and tablets, consumer electronics companies have continuously tried to innovate by going smaller. It was this evolution from compact, mobile personal technology to wearable technology that was on full display this year at CES. There were smart watches, smart jewelry, and smart glasses, and even mention of integrating technology into fabrics. There was a visible trend toward fashionable, smart, wearable health devices. The core technologies and functionality in many of the wearable gadgets on display were fairly similar, mostly informational apps and health and fitness monitoring, but it was the emphasis on style and technology as an accessory which spoke to how health technology will be more seamlessly integrated into everyone’s everyday life.

After years as a novelty, in 2013 wearable health tech began gaining wider adoption. From primetime TV commercials for the Samsung Galaxy Gear—a watch reminiscent of Dick Tracy’s clunky walkie-talkie wristwatch—to coverage of the debut of Google Glass on local news channels, wearable technology was noticeably all over news and pop culture. You couldn’t take a ride on the New York City subway without seeing at least 5 people with some kind of fitness tracker on their wrist or hip. And those who didn’t have a dedicated tracker likely had some kind of fitness or health-focused app installed on their smartphone. In fact, wearable tech adoption grew from 3% in 2012 to 13% 2013, and that growth has been fueled by growing consumer interest in fitness and personal health monitoring and tracking. As consumers have increasingly begun to take control of their own health, adoption of wearable devices to help them do so has grown. Gartner predicts that the fitness and personal health monitoring trend will grow to a $1.6-billion industry in 2014 and to $5 billion by 2016. As we saw at CES, consumer electronics manufacturers are doing their part to give the trend momentum by making the wearable devices easy to use, fashionable, and less pricey, hoping to appeal to a much wider consumer base. And it’s not just the consumers who will see the benefits of devices that are easier to have and use. New opportunities will continue to arise for healthcare professionals and pharmaceutical companies to play a direct role in wellness and health behaviors through these wearables. As open software standards become more prevalent across devices, it’ll be easier for healthcare marketers to customize programming to suit clients’ needs and integrate wearables into a more personalized patient experience. Here at Ogilvy CommonHealth Worldwide, we’ve already begun to explore how this new channel for engagement can be used toward patient education and adherence. Next Christmas, don’t be surprised if your grandparents or teens ask Santa for a fashionable wearable health device.

What about you? Do you currently own a wearable personal health or fitness device? How has this affected how you manage your and your family’s health?

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LIVING THE BRAND—Awakening the Senses at Congress

conventionIt seems that the time has passed when having more sales reps and a bigger booth at a major congress was enough to attract physicians to learn more about your brand. Beyond the financial and compliance challenges that the industry has encountered in the past decade, leading in part to decreasing attendance from physicians, clients as much as agencies are continuously looking for new ways to catch physicians’ attention.

What if physicians were just like us: curious and playful

At times, new data just doesn’t make the cut in the clutter of a congress…and let’s not mention when there is no new data to present. Of course, physicians are interested in learning more about a new product, indication or technique. However, in today’s reality, it just doesn’t seem to be enough. Having physicians engage with the brand in a fun and truly unique way can actually set the ground for a deeper relationship and more memorable experience.  What if detailing on touch screens, offering games or iPad quizzes, to name a few, were already not enough in this rush for new things? What if physicians were just simply looking to (re)connect with brands whilst having fun?

Success lies in the story you tell and how you tell it

Going beyond the usual techniques to drive interest at congress requires us to take a step back and look to the core of what the company, brand or product stands for. What it means for your client and physicians. After all, congresses are a great opportunity to reach a maximum of physicians while bringing your vision to life. The booth and activities around it, including symposia, then are used to articulate this story.

But how to define the story you want to tell? One way to do so is to look at the company or brand ambition. What they want to change or bring in this world, where they make a difference. Another way is to leverage the unique features of the product (eg, physical properties, MOA, mode of administration, unique manufacturing process, etc).

What do you do once you have a clear story? You offer physicians a sensory experience. This is when curiosity and playfulness come into place. Perceiving, feeling and doing will create a true brand experience. Knowledge is only one part of a person’s understanding.

Two client cases can help illustrate how senses can create emotional connections. An ophthalmic pharmaceutical company, living by the vision of “leading a brighter future,” and whose main products are hydrating eye drops, articulated their booth activity around a water light graffiti. As physicians were writing on the wall with water, the surface of the wall made of thousands of LEDs was illuminating. The client got their main message across: water is essential for the eyes to properly function, and light is an important medium for sight.  Another client, a leading dermatology company, developed a full sensory experience to differentiate its new dermal-filler range at launch and demonstrate that each product was customized to fit physicians’ needs. During a major industry event, physicians were welcomed into an experiential room. They were able to walk around and visit various custom-made “tools” to feel and see the products (eg, an injection bar,  a gel texture tool to touch the products, and a visual tool  to play with product elasticity). Both cases were based on the core of the brand vision and did create a memorable journey for physicians.

What will experiential activities do for physicians and your clients?

Physicians are keen to interact with their peers and such activities will make them want to share and tell. Word of mouth will not only drive traffic to your activities but also create brand awareness. Physicians will remember your client’s brand and the experience they had with it. They will probably want to engage with it after the event. Creative executions will also differentiate your client and position them as innovative and bold.

Brand experience is about going back to the basics: our senses

OCH Paris won a 2013 Global Award in the category Art & Technique: User Experience (click here to access the Global Awards website

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Engaging EU Health Policymakers

While newspaper headlines and some segments of the public question the future of the European Union, the reality is that the EU’s impact is growing, both at a national level in its 27 member states, and globally. The EU is the largest market in the world in terms of Gross Domestic Product (GDP). EU political institutions develop regulations and directives that are transposed into national laws that affect a half-billion people living in the EU member states. So how can organizations and industry with an interest in health engage with the EU institutions which, for many, seem distant and far removed from our daily existence? And for that matter, especially when it comes to healthcare issues?

The short answer—it’s not that easy! The first thing to remember is that the 27 member states are entirely responsible for financing, organizing, managing and running their health services and national health policies—and they protect this fiercely. The EU has limited competency when it comes it health, but it plays an important role in:

  • Standard setting and regulation in specific areas such as pharmaceuticals, medical devices, blood products, and organs for transplantation
  • Ensuring that there is a high level of health protection in all EU policies and actions
  • Assisting member states to coordinate their actions and collaborate on health
  • Taking joint action with governments on “threats to health,” particularly where there is a cross-border dimension

There are a number of important players to consider: the European Commission (effectively the civil service), the European Parliament, with its democratically elected Members of the European Parliament (MEPs), and the European Council, which is where the member state government representatives appear. You need to be aware of how they interact with one another, who they are hearing from, and what they are talking about. So with this in mind, what are my top tips?

  • Know the key players in the institutions, where they sit in the debate, and where they fit into the legislative process. Talk to them early and aim to build long-term relationships.
  • You need to build credibility and alliances—at EU level, this needs to be multinational, cross-party, multistakeholder engagement.
  • Engage the member state governments in their country and in Brussels through their EU missions, and work with your stakeholders to do the same.
  • Now more than ever, there are limited national budgets and EU-level resources, so taking on single-issue, disease-specific approaches will be more challenging. A prevention angle, which helps alleviate the problem, is more likely to resonate.
  • Work closely and respectfully with others. Don’t approach politicians with an overwhelming shopping list of topics and issues, and little understanding of the processes involved. Keep in mind they are dealing with a wide variety of issues on a day-to-day basis.
  • People have very limited time—don’t waste it. Campaigns need to be tailored to the audience—mass market communications, post-card campaigns are archaic and annoying.
  • Use targeted social media to support your messages. Many politicians and advocacy groups are online using Twitter. Get involved in these conversations in a meaningful way.
  • Above all, be transparent about who you represent and the issues you are interested in—politicians and officials will never speak to you again if you mislead them.

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