In a bid to appear communicative, concerned and transparent, PhRMA created an Office of Accountability two years ago to collect comments about compliance with its 15 'Guiding Principles' on DTC ads. The office is supposed to forward remarks to drugmakers, and issue periodic reports to the public about these comments and what, if anything, drugmakers did in response.
Today, the second such report was disclosed and what do we learn? Not a heck of a lot. Instead of insights into issues with any specific ad or substantive examples of the kind of reactions that may have been taken, we get two basic charts that, essentially, tally the number of comments. John Mack at PharmaMarketing calls this a 'whitewash.' That's being generous.
PhRMA is a trade group, not a watchdog. So there's no reason to expect the organization not to sugarcoat. But if PhRMA really does want to contribute to the discussion about DTC ads - and inspire a little confidence and goodwill - it'll have to do more than provide vague and fluffy summaries. Next time, PhRMA should include verifiable comments, specific examples and responses by drugmakers themselves.
Keep reading to see why...
Drugmakers said they received a total of 458 comments during the second six months of 2006. Of those, 330 comments, or 72 percent, were about TV ads and 128, or 28 percent were about print ads. Most of the comments - 271, to be exact, came from patients or consumers, while 28 were submitted by health care professionals and two came from other sources.
More than 60 comments were public health benefits of DTC ads, such as disease and product awareness, which is covered PhRMA's Principle #1, and more than 30 were recieved concerning compliance with FDA regulations, which is Principle # 2. But what issues did the remarks raises? PhRMA isn't saying.
"The comments on Principle 1 were both positive – with many patients having favorable reactions to the educational component of an ad – and negative – primarily with regard to specific actors used in the advertisement. The comments on Principle 2 dealt primarily with the need for clarification around the specific details of an advertisement."
One episode is hinted at - a company revised an ad in response to a comment. But that's all we get to know.
When it came to Principle #3, which is educational value, the 21 comments were "appreciative" or reflected "confusion." Most of the comments about risk info, which is Principle #11, expressed more confusion.
But there were "very few comments were received on Principles 4, 5, 6, 7, 8,9 , and 10."
Then there were the 43 responses to Principles #14 and #15, which encourage companies to promote programs about health, disease awareness and for the uninsured. These were "overwhelmingly positive - thanking drugmakers for offering product assistance and asking for further information." Oh yes, there were a few negative remarks about perceived insensitivity to those suffering from a specific disease.
Here's the report, which includes the 'Guiding Principles.'