Pharmaceutical Companies and Search Results ComplianceMay, 2014

Pharma and Search Compliance – Marcos Richardson

Introduction

Pharmaceutical and healthcare companies own websites to impart information about their company,products and services. With strict country regulations on how medicines can be promoted to publicconsumers and Health Care Practitioners (HCPs), the contents of these websites are carefully targetedat either consumer or doctor and must abide by country regulations (FDA, PMCPA etc.).

One specific and basic principle of an online presence is, however, being overlooked, ‘Search EngineResults’.

This paper looks at two search components (from an optimisation perspective and a complianceperspective) that are publicly visible in search engine results: the ‘Title Tag’ and the ‘Description Tag’.

What are Search Engine Results and Why are they Important?

A search engine result is the information a person sees after performing a search query and it lookslike this:

Search results are important because they are the first piece of information a person sees beforeclicking and entering a web property. This is a billboard of advertisements enticing people intotaking the next step and choosing which site to visit.

From a regulatory compliance perspective, this is the information that describes what a searcher islooking for based on their query and what the searcher is likely to see if they continue on into thewebsite. This public information needs to be complete, accurate, and considerate of the mixedaudience that will see the promotion.

*source: http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/ucm338405.htmhttp://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/EnforcementActivitiesbyFDA/WarningLettersandNoticeofViolationLetterstoPharmaceuticalCompanies/UCM221325.pdf

Components of Search Results

Title and Description tags control what becomes visible in the search results. Both the Title Tag andDescription Tag are individual components within the HTML of a web page. Companies can governwhat is displayed in the search results by controlling what is placed within these two elements.

Title Tags are widely known to have search engine ranking value, whilst Description tags have lessinfluence on ranking results but are the main mechanism for endorsing the web page prior toentering the website.

Effect on Regulatory Compliance

‘Metadata should reflect the content of the site and not be promotional’ (*PMCPA and ABPI), The FDAexpects submission of metadata and Failure to submit is not acceptable.

The FDA’s implied knowledge of Metadata is based on two cases (1. *FDA warning letter sent toMedical Doctors Research (MDR) 2.) * FDA's letter to Novartis citing violative content in a Facebook‘Share Widget’ that Novartis created as part of the Tasigna website metadata.

Google is an advertising platform and directory. You can either choose to pay for your advertisementsand receive guaranteed clicks/visitors or, by allowing your website/content to be available on Google,you list all of your web pages free of charge for the public to see. Either way you are promoting yourcontent.

Doctors, medical writers, legal specialists, brand specialists and specialist agencies are employed tomake certain that the right information on a website or social channel is made available to the rightaudience.

The same due care and diligence needs to be given to the metadata that is visible to the public priorto entering the website.

PMCPA

Title Tag

Description Tag

Pharma and Search Compliance – Marcos Richardson

Pharma Search Results Examples

Pharma companies are ignoring Metadata and the result is quite often an incomplete message and, inmany cases, a non-balanced promotion.

Here are some good and bad current (May 2014) examples where descriptions are not complete andthe message unbalanced (N.B. These are all prescription drugs that carry warnings of potential fatalityif taken). Note in many cases the message is truncated (cut off) this is not a deliberate fault of thecontent suppliers but an inadvertent result of not applying search engine best practices.

Pharma and Search Compliance – Marcos Richardson

How to Fix Meta Data

As part of the content creation and the regulatory compliance sign off procedure, include the Titleand the Description of each page.

There are certain pages that require more diligence than others, such as product safety information,product characteristic, product description, dosing information, adverse reactions and side effects.

The Title has a maximum limit of 80 characters before the copy is truncated and the description has alimit of 155 characters before the message is cut off.

Element Optimised Character Limits

Title Tag length 65-80

Description Tag length 140-155

Within the description, if there is mention of brand and generic names, no claims or representations(or product indications) should be made.

If diseases or conditions treated by the product are mentioned, no claims should be made.

Whilst regulations in the EU vary, they can be more restrictive and therefore the suggestion is to overcomply.

Example

Element Optimised Character Limits

Meta Title Brand (generic) [section of website] Official Website [uk]

Meta DescriptionInformation for patients about ‘Brand’. View product and important safety information, including black box warning.

provide links to product, important safety information

Pharma and Search Compliance – Marcos Richardson

Interesting Facts

Lawsuits are on the increase in the Pharma industry and the majority are based on marketing claims.

Between 2000 and 2012 the industry paid more than $30billion to settle 226 violations in the USA.

183 patent settlements between originator and generic drug makers were concluded in the EuropeanUnion (EU) in 2012, compared to 120 in 2011.

77% 84%

*Health seekers begin their research at a search engine

*HCPs Use Online Resources Daily

*Source: Google and HIMSS Analytics, “Hospital Decision Makers Study,”*Source: Google & CEB’s Marketing Leadership Council, B2B Digital Evolution, February 2013

Pharma and Search Compliance – Marcos Richardson

Interesting Facts

Whilst there is a general understanding and acceptance that Paid Search (PPC) has restrictions forPharma companies, no such restrictions are in place for Natural (Organic) Search engine listings.

… and 94% of visitors click natural ‘Title’ and ‘Meta’ description results compared to paid results

*Natural Traffic Share

94%

Google AdWords restricts the promotion of healthcare related products and services. We have different requirements for advertising healthcare-related products based on the product you're advertising and the country you're targeting.

“We do not generally allow the use of prescription drug terms in ad text, landing pages or keywords, though there are country-specific

exceptions that only apply to registered pharmacies and licensed pharmaceutical manufacturers”

https://support.google.com/adwordspolicy/answer/176031?hl=en#country

*Source: GroupM UK and Nielsen

Pharma and Search Compliance – Marcos Richardson

Recap and Takeaways

Consumers and Healthcare practitioners are searching for information online and they look at naturalsearch engine listings when they are making decisions on what content to view. Regulators areincreasingly becoming aware of metadata. When Healthcare companies choose to take part and usewebsites and digital assets to promote products, all publicly visible content should be regulated.

Develop regulatory compliant Metadata (Title tags and description meta tags) If there is mention ofbrand and generic names, no claims or representations (or product indications) should be made.Similarly, if diseases or conditions treated by the product are mentioned, no claims should be made.

Add metadata to your content approval process1

Work within the allowable search engine character limits for Descriptions and Titles2

Take a priority approach and apply regulated metadata to sensitive content pages such as proscribing information and indications.

3

Meta descriptions should be written to either include fair balance, or to omit the drug indication (i.e. a generic, non-product related statement.)

4