The latest Instagram influencer frontier? Medical promotions.

By  | Feb 26, 2019 05:13

Louise Roe has denim that’s ripped in all the right places, a bikini-ready body year-round, a husband and baby who look like they were picked from a catalog, and 698,000 Instagram followers. She also has the skin condition psoriasis, a chronic autoimmune disease defined by flaky, inflamed red or white patches of skin, and she wants you to know all about it.

Actually, she needs to tell you about her psoriasis on Instagram; otherwise, her paid partnership with Celgene, a biotechnology company that produces the patent-protected psoriasis medication Otezla, would presumably be canceled.

In recent years, businesses have adapted their advertising strategies to the rise in social media use, specifically on Instagram. The app is one of the most popular social networks, surpassed only by its parent company, Facebook, and is projected to have more than 1.1 billion users in 2019 — more than half of whom are between ages 18 and 29. The high level of Instagram user engagement gives companies an opportunity to capitalize on users with thousands of followers, aptly dubbed “influencers,” through paid advertising partnerships.

These Instagram ads, for which influencers can be paid an estimated $1,000 per 100,000 followers, are selling not just a product but an entire lifestyle. Rather than buying a single-page ad or a minute-long TV or radio spot, companies benefit from the candor and storytelling on influencers’ feeds. However, selling a pair of shoes or luggage as part of a lifestyle is far different from selling pharmaceuticals, medical devices, and other health-related products. Nevertheless, pharmaceutical and biotech companies and Silicon Valley health startups see the opportunity Instagram presents and are increasingly using influencer-advertising as a way to increase their bottom lines.

In a pink tutu against a pink backdrop, Erin Ziering, wife of former 90210 star Ian Ziering, advertises Allergan breast implants and Botox side by side in a December 2018 post — the same month the company pulled its textured implants from European markets in response to a notice from the Food and Drug Administration that individuals with breast implants are at risk of developing breast implant-associated anaplastic large cell lymphoma (BIA-ALCL).

Ziering’s post uses #Ad near the top of her caption, but what follows focuses on breast cancer awareness and not either product’s risks and benefits. Instead, users need to click through multiple photos to find this information, which elides the risk of BIA-ALCL. Neither Allergan nor Ziering responded to requests for comment.

“The blatant pushing of a product that preys on women’s insecurities doesn’t sit well,” says one woman who underwent breast reconstruction and experienced complications associated with BIA-ALCL. Speaking with Vox about Ziering’s post on the condition of anonymity, she said that by combining Botox and Natrelle in the same ad, “the company is trying to profit or push a product [Botox], which is literally a toxin, while promoting breast cancer awareness … sounds contradictory.” When asked about the post-tutu photos, which contained relevant risk-benefit information, she said she “didn’t even realize that there were more pictures.” The FDA issued another letter about BIA-ALCL to health care providers on February 6.

Allergan is not the only company that markets to and, inevitably, tries to take advantage of vulnerable women. Bloomlife is paying mommy bloggers like Alyson Owen and Stephanie Peltier to tell fellow pregnant women that they can save a trip to the hospital by monitoring those pesky contractions at home. The device does not require FDA approval, only registration, as its intended use, according to the company’s website, is as a “health and wellness device and not a substitute for medical attention.” However, neither Owen nor Peltier’s post includes this important advisory; Owen’s goes as far as labeling it the “world’s first clinically validated wearable contraction monitor,” a phrase that may be misinterpreted as “FDA-regulated” by the average consumer.

When reached for comment, Bloomlife would not clarify the intended meaning of “clinically validated” and noted it does not have a large paid-influencer program, labeling it “more organic.” Only Peltier offered comment on her paid partnership with Bloomlife, noting her positive experience working with them. She said the company sent her “guidelines explaining a bit more about the product and ... what I could and couldn’t say. … [T]hey wanted to be very careful that, as an influencer, I wasn’t making a bunch of unsubstantiated claims,” like calling the product a “medical device.” Beyond these recommendations, Peltier was free to write her own caption and accompanying blog post.

By omitting or misrepresenting critical health information or failing to present multiple options for treatment, as a physician would do with their patients, influencers run the risk of leaving their followers with a possibly dangerous, largely incomplete kind of hope. There is no doubt that this type of health care advertising-cum-storytelling is effective — and is frequently compliant with federal regulations. But there’s a more important question we need to be asking: Is it ethical?

Health care sponcon is here to stay, but at whose expense?

What’s being advertised matters as much as how it’s advertised. Technological advances have led to a boom in the pharmaceutical and medical device space. The treatments we see hashtagged are new to market or still under patent protection, and therefore, manufacturers need to make a compelling case as to why their product is better than an older but similar generic option supported by years of research.

These generics, whose active ingredients are the same as their brand-name counterparts, are preferred by insurers and physicians because of the product’s cost and research that support its benefits. While generics compete based on price alone, brand-name treatments depend on name recognition and storytelling in order to recoup the $1 billion or more spent on development of each new product.

By enlisting influencers to market their health care products amid a stream of Facetuned photos, pharmaceutical and biotechnology companies co-opt narratives that give social media users a sense of how healthy they can be, if only they had this product. This is why Roe, who did not return requests for comment, is the perfect ambassador for Celgene. There’s no sight of psoriasis on her Instagram feed; her skin is clear, perfect even, and she’s smiling in every picture — and the message implies that if you buy Celgene, you can have that too. In selling Celgene, Roe is also selling a life — her life — but what she does not tell you is Celgene does not work for everyone and it certainly won’t give you her life.

The pharmaceutical giant, which was recently acquired by Bristol-Myers Squibb for $74 billion, is no stranger to deceptive advertising. In 2016, the FDA Office of Prescription Drug Promotion notified the company that a TV ad for Otezla, the same drug Roe promotes, was “misbranded” and “creates a misleading impression” about the drug’s safety. The agency’s reasoning was that the ad’s “compelling and attention-grabbing visuals and SUPERs, all of which are unrelated to the risk message … compete for the consumers’ attention.” The same could be said of Roe’s multiple paid posts for the brand. Bristol-Myers Squibb referred Vox to Celgene for comment; Celgene did not respond.

The goal of a successful ad campaign is to minimize the degree to which it appears like an ad. This is especially true for ads targeting millennials, who make up the largest group of Instagram users and will accrue $1.4 billion in spending power by 2020. Instead, it needs to tap into consumers’ needs, buried deep in their subconscious. With respect to Instagram advertising, this can be problematic because a consumer might associate a product with an influencer’s entire feed rather than the information presented in a single ad. To add insult to injury, some patient influencers — who have every financial incentive to promote their products “authentically” — may omit critical health information, thus deceiving potential patients.

Who’s responsible for regulating these posts? Good question.

In 1905, author Samuel Hopkins Adams published a series of articles on “patent medicine evil” in Collier’s Weekly titled “The Great American Fraud.” It brought to light the addictive and poisonous ingredients in medicines marketed for children. Soon after, the 1906 Pure Food and Drug Act was passed, which charged the FDA with regulating how companies communicate the risks and benefits of every drug and medical device that the agency approves — but only on the labels attached to those drugs. Before 1962, the advertising of prescription drugs and medical devices remained the responsibility of the Federal Trade Commission.

The FTC is responsible for consumer protection in all industries; within health care that includes the entire non-prescription side of the business and certain classes of prescription devices (all of which are registered with the FDA), according to an FTC spokesperson. Historically, patients and consumers were considered separately, but now that advertising targets specific patient populations in broadcast, print, and online media — giving them the information and power to demand a particular medical intervention — consumers require different protections, and both agencies fall short in providing them.

Both the FDA and FTC have federal rulemaking authority, which means they can create guidelines for advertisers that support laws already passed by Congress, and health care sponcon falls under the purview of both agencies. However, the guidelines both agencies publish are, as per both agency’s spokespeople, intentionally vague.

According to the FTC Advertising Practices Division, the agency does not “tell people exactly how they should phrase things in most cases, but [does] tell them what choices they have and what range of options they have if they want to stay on the right side of the disclosure line.” Similarly, nearly every guideline published on the FDA website is labeled as a draft and begins with the following disclosure: “[The guide] does not create or confer any rights for or on any person and does not operate to bind FDA or the public.”

Despite the leeway companies are given, federal guidelines do have an impact. Now, when we see Ray Liotta appear on television explaining how he quit smoking using Chantix, it is apparent the ad is regulated — and that Liotta was compensated for his endorsement — because of the disclosures scrolling along the bottom of the screen. The same risk-benefit and financial disclaimers are applied to social media advertising. According to the FDA, advertisements for pharmaceuticals and medical devices must give a balanced description of the product, meaning an ad cannot focus solely on the benefits of its use if there are known risks that could alter the patient’s decision to use a particular product.

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