By Matthew Brown, Director Paid Search, Dentsu Health

The use of paid search advertising by pharmaceutical marketers is often regarded as “table stakes”, a must have tactic in your paid media arsenal that responds to precise moments in the patient journey unlike any other paid channel.  The importance of search engine marketing (SEM) means pharma marketers must stay on top of the latest changes and innovation while balancing the ever-complex global regulatory environments.  Most recently the shift from (ETAs) to (RSAs) caused discomfort for some Med Legal teams as the new world of dynamic ad combinations meant less control.  And now as we approach a new era of AI, pharma marketers and their agencies will need to embrace the opportunity while navigating legal & regulatory complexities.

Starting in June 2022, RSAs became the exclusive ad creation pathway provided to marketers on the major search engine platforms. They allow advertisers to upload multiple headlines and descriptions, then let machine learning customize the different ad variations based on the user’s search behavior. The main goal of this ad format is to increase engagement while allowing the system to optimize as time goes on.

Due to the automated ad-generation process and how assets are dynamically selected across Google and Bing, the variable display features of RSAs present regulatory compliance challenges for prescription drug promotion.

Because of this, the Dentsu Health search team joined an hosted by the at the end of last year on response search ads (RSAs) and their use in prescription drug promotion. We used this as an opportunity to:

• Better recognize and assess the challenges presented to prescription drug sponsors by RSAs
• Develop new strategies to ensure prescription drug promotion through RSAs is compliant
• Adapt our existing submission processes to incorporate RSA best practices with the emergence of new technologies

This roundtable webinar was moderated by Jason Cober from the  and included other pharma industry representatives with a deep knowledge of RSAs. Panelists discussed best practices, lessons learned, and strategies to ensure prescription drug promotion through RSAs is both effective and compliant. The most important topic we wanted to share some highlights was around AI, specifically on: What are the best practices around RSA development and how can marketers apply this with the evolution of AI?

Use a Proper Submission Template

• Create an organized template that can be used to review all the components of a paid search campaign (keywords, ad copy, and extensions). Set up the template so the brand marketing team and promotional review committee can easily review everything that is submitted for approval, and most importantly, what each combination of the ad units could say. Also, consider setting up the template so you minimize any errors when uploading the approved copy to the search engine platforms.
• Have branded and unbranded keywords and assets in separate documents. This will ensure the brand name is not accidentally mixed with the condition and to avoid making a claim in a brand reminder ad.
• Include safeguards to manage copy character limitations. Every component of a RSA is character limited, so inputting formula alerts will ensure all lines of text are within the threshold that search engine platforms allow.

Use a Proper Pinning Strategy

• Prescription drug regulations require that certain information be presented to remain compliant, but RSAs might not always include all lines of the text. Since the first and second headlines and the first description are only guaranteed to show, markets must ensure all required information is pinned in those positions. For example, the brand/generic name should always be pinned in the first or second headline, but you may need to get creative if it doesn’t fit, so it may have to be incorporated into the first description line. For black-box drugs, the boxed warning should always be pinned in the first description.
• You also need to ensure the required information is presented in every ad, which leads to the next challenge, variability. Considering you could have 43,000 different permutations of the ad, and certain lines of next might not always be present, you could easily land in a place where an add is displayed that doesn’t include the required info or accidentally makes a claim when it’s intended to be a brand reminder. So, this is why it’s extremely important to have a solid pinning strategy to ensure compliance for each possible combination of the add.

Education & Communication

• For every paid search submission, make sure to plan in advance and have open line of communication between the promotional review committee and brand marketing teams. This will ensure that the agency has enough time to properly prepare and give the marketing team time to review prior to expiration dates or site launches.
• Provide proper education to ensure that every person involved in the review process understands the functionality of RSAs. Whether it’s the promotional review committee, brand marketing team, or agency, having a walkthrough about how RSAs work will allow for a smoother review process. It also gives enough time for all parties to ask questions and feel comfortable about what exactly is being submitted for review.
• Since pharma is a restricted vertical across Google and Bing, having a consistent line of communication with your agency reps will keep you up-to-date on what can actually be activated across the major search engine platforms.

For search marketers working within a restricted vertical and needing to follow compliance requirements, we don’t always have the luxury of utilizing all of Google’s auto-asset suggestions. So, the future of AI for pharma search is really going to come down to how marketers analyze the asset suggestions and recommendations to judge what we can get approved from a MLR standpoint.

Learn more or get in touch with Dentsu Health at