Since these have gone up before the agency formally posted them online, the actions have created additional uncertainty and urgency within the industry.

However, as the dust settles, it has become increasingly clear that while the intention is to disrupt the status quo in medical marketing, both drugmakers and their agency partners don’t need to break the glass in case of emergency just yet.

Still, Avalere Health CEO Amar Urhekar implored drugmakers to understand the policy updates coming out of Washington, D.C. and adjust their workflows to continue to meet the needs of the people they serve.

“This is not the time for siloed working,” he said. “Direct-to-consumer, HCP, patient advocacy and policy specialists all need a seat at the table to discuss how we engage our audiences and customers, creating a new path forward that informs and empowers every patient and healthcare professional to make the best decisions possible.”

What are the proposals?

It’s important for medical marketers to recognize that the Trump administration’s proposal is not a ban on DTC advertising.

While such efforts have been mulled over in Congress and mused about within the Trump administration in recent months, this is an executive action.

More specifically, it’s a presidential memorandum — a lesser form of an executive order, according to James Potter, executive director of the Coalition for Healthcare Communications.

In addition to the proposed crackdown on deceptive drug advertising, the White House is directing the FDA and HHS to require full safety disclosure on drug advertisements.

Dunn took umbrage with the assertion in the HHS fact sheet that the risk statements in pharma ads are not designed to be conspicuous.

She countered that they are specific and call attention to the most significant side effects of drugs as well as actionable risks that a patient can recognize.

“The idea that we are hiding or undermining this information is absolutely the furthest thing from the truth, like everything else that we see,” she said. “It’s undermining the entire physician-patient relationship and the entire medical community should raise an alarm about this.”

Potter added that, at this time, these actions should be seen as more of a chilling effect on DTC pharma ads rather than an outright ban.

He advised drugmakers against capitulating to administrative threats and reiterated the potential for legal challenges if more aggressive steps are taken against pharma ads.

Pharma brands, medical marketers should stay the course

The overwhelming sentiment among medical marketing leaders is to digest this announcement and stay the course.

Milena Sullivan, practice director of policy at Avalere Health, echoed Potter and said that the statement from the White House is far from a policy implementation.

“We still have a couple of steps to check off before this becomes a finalized policy that everyone in the market has to comply with,” said Sullivan.

She added that this is not the first time the Trump administration has tried to reform pharma ads, referencing the administration’s efforts to limit direct to consumer advertising during Trump’s first term.

“Under the first Trump administration, we saw some momentum build around outright bans of drug marketing or the focus of transparency being more on prices rather than on medical information,” said Sullivan. “Both of those efforts were not successful, because at the end of the day, there was a need to raise awareness of rare conditions and find ways to reach those patients — especially for underdiagnosed or stigmatized conditions.”

She added that the rise of education campaigns and delivery of medical information has grown over the past two decades, and that a direct outright ban on direct to consumer drug marketing would be “untenable.”

Interestingly, Sullivan also mentioned that the White House’s strategy to reform DTC advertising is its way of indirectly targeting the high cost of prescription drugs.

“It’s not dissimilar to back in 2018 when he tried to tackle drug pricing. There is very explicit acknowledgement in the announcement referencing data that they have on how they view the connection between DTC marketing and drug prices,” Sullivan added.

She touched on the Trump administration’s subdued strategy on how cutting DTC pharma ads could lead to less utilization of pharma products because of reduced exposure, and that it could potentially influence the cost of drugs.

She concluded that this strategy, however, has not worked in the past.

Ryan Mason, chief strategy officer at Avalere Health, agreed. He advised pharma marketers to focus on doubling down on educational campaigns, and be wary of the channels they use to roll out information.

“What we talk about in the industry now is to create reminder ads that mention the name of a therapy or it might be more about disease education itself,” said Mason.

However, he also advised brands to review their current advertising strategies.

“The best thing to do in those cases is to review and audit what we are doing, and make sure that they feel confident that they’re in compliance with the current spirit and letter of the law,” said Mason.

Opportunity to revise DTC approach

While the proposals themselves may not be an immediate issue for drugmakers, the timing of the rollout is.

Dunn noted that most companies have a fiscal year that begins January 1, so they are finalizing their 2026 planning budgets, which likely include significant investments in DTC.

She added that the chief concern for Hale Advisors is ensuring its clients remain compliant and knowledgeable about the recent changes affecting their marketing plans.

“One thing we are telling everyone is that they need to retrain and ensure that their entire teams are aware of DTC clear, conspicuous and neutral (CCN) requirements,” she said. “Also, that they are clearly evaluating their internal standards and guidelines around DTC while continuing to stay the course and do the right thing.”

Though the timing may be difficult, there are opportunities for drugmakers to revise their approach to DTC marketing.

Dunn advised clients to undergo a comprehensive review of their marketing approach and investigate where their investments are going to have the most impact and benefit for patients.

James Ramelli, a partner at Fyllo, a digital marketing agency, added that marketers should hold off investing in long term marketing strategies just yet, or at least until more information on policies around direct-to-consumer advertising becomes clear.

“As you know, it’s not fully clear yet exactly what these regulations are going to look like,” said Ramelli. “I would look at more nimble and maybe short flight messaging strategies, maybe cutting the year up into smaller pieces. I would also probably start to invest in more agile types of content pipelines.”

If restrictions to DTC advertising are implemented, it could have negative effects on access to life-saving products, said Alex Schriver, SVP of Public Affairs at PhRMA.

“This move by the FDA will make it harder for patients to access valuable information they need to have meaningful conversations with their doctors. Direct-to-consumer (DTC) advertising on prescription medicines provides factual and research-backed information that helps patients make informed decisions about their health care and treatment options,” said Schriver.