The pharma industry is set for a battle as the Trump administration and trade group PhRMA offer competing solutions to putting drug prices in TV ads.
Health and Human Services secretary Alex Azar unveiled a proposal to require drugmakers to put the list price of medicines in their direct-to-consumer advertising.
The move had been talked about for months as a way to increase transparency and contribute to lower drug prices. President Donald Trump floated the idea in May when the administration unveiled its drug pricing blueprint.
The proposal is open for public comment until mid-December, so changes to DTC ads would be months away. Yet if implemented as the proposal stands, the next time a TV ad for a new preventive migraine drug appeared, the list price of a $575 monthly dose would need to be included, too.
“The proposal creates a difficult quandary that promotional messages [about drugs] must be truthful and non-misleading, but inherently to present some list prices as the actual price of a drug is misleading,” said Jon Bigelow, executive director of the Coalition for Healthcare Communication.
The argument against the HHS proposal is few patients will actually pay that $575 for the drug after it goes through the complex system of pharmacy benefit managers’ negotiations, rebates, and their individual insurance coverage.
Transparency’s challenges
The industry is already on the defensive. Hours before Azar’s speech, PhRMA released its own approach to drug price transparency, one that was much friendlier to pharma companies than his. PhRMA announced its member companies will begin using DTC ads to direct consumers to more information about a drug’s price, including list price, out-of-pocket costs, and financial assistance, instead of stating the list price outright.
The alternative proposal is modeled after other FDA requirements on pharma ads for lengthy prescribing and safety information in TV ads.
Instead of putting the entire prescribing information in the ad, it can instead direct patients to a website, magazine ad, phone number, or their doctor for the additional information.
The HHS proposal leaves questions from the industry, said Megan Olsen, senior director at Avalere Health.
“There are still several outstanding questions both about how this would work, what implications this would have for patients and drug prices, and regarding the enforcement mechanisms, as currently outlined there isn’t a single primary enforcement,” Olsen explained.
“Folks are expecting potential legal challenges as a result of this proposal, depending on how this moves forward.”
Because of these outstanding questions, the timeline for implementing the HHS proposal is more unclear than usual, she added.
In the meantime, pharma marketers should begin preparing for changes to DTC ads, experts say.
One change could be longer TV ads. Pharma’s 60-second ads are already packed with side effects and risk information, so adding another required element could push them over the one-minute mark.
With TV ads usually sold in 30-second intervals, pharma ads may include more 90-second buys.
Engaging consumers
That could mean even more money spent on TV advertising, which already accounts for 63% of all pharma ad spend, according to Kantar.
It also begs the question of whether consumers will even pay attention to a drug ad for longer than a minute when smartphones are already drawing attention away from commercials.
Indeed, the attention span on TV and video content lapses after 15 seconds, and in a mobile world, people look at their phones during TV spots.
“There comes a point where the ads stop being effective because it’s not engaging people when you’re adding a lot of extra information that might not be relevant to the viewer,” noted Carly Kuper, SVP of public relations and corporate communications at CMI/Compas, which is advising clients to begin discussions now to prepare for such broadcast media implications.
Bigelow also suggested pharma marketers start thinking about how to incorporate more information into a TV drug ad, whether that’s looking to shorten another part of the ad or extend the commercial length.
Moreover, with issues such as high drug prices and healthcare reform top of mind after the midterms, pharma marketers should keep an eye on the public’s pulse.
Kuper said upping social listening to get a gauge on public perception during this tumultuous time could be helpful for building future drug ads.
Americans are generally supportive of drug prices in advertising. A Kaiser survey in June found three quarters approved of the idea overall, and it held steady across all political affiliations, with 83% of Democrats, 73% of independents, and 72% of Republicans supporting the idea.
“Knowing what customers want is important because if [the proposal is implemented], then how do we modify ads so we’re able to help consumers make good decisions?” Kuper inquired. “If we have to lengthen the ads for TV to allow the [price] information, how does that change things? Is that something that actually isn’t a big deal for people? Seeing what other creative and interesting ways we can help people be able to access the medicine they need is something pharma companies excel at.”
Both Bigelow and Kuper, like many in the pharma industry, agree more with the PhRMA proposal.
Their thinking, like PhRMA’s, is that the proposal gives viewers context for the price, and an idea of what they might pay when they get to the pharmacy counter.
“The important takeaway is there is significant public anger about high drug prices and something is likely to be done,” Bigelow said. “Both parties are flailing for solutions for high healthcare costs when the rational discussions for high healthcare costs are contentious. One or both proposals will have some effect either through HHS regulations, legislation, or through a deal between the Trump administration and the pharma industry.”
From the December 01, 2018 Issue of MM+M - Medical Marketing and Media
