Rewriting the DTC Playbook: 2027 Brand Planning Edition

By Seth Gordon, Executive Vice President, Medlive 

The main question I hear from DTC marketers is where does my budget go next? Here’s my answer. 

Every Direct-to-consumer (DTC) brand team I talk to is evaluating their 2027 strategies against the same concern. DTC advertising has always been a safe bet, with tens of billions spent on it every year.¹ That’s changing.  

The FDA’s proposed rule, “Transparency in Direct-to-Consumer Advertising,” is moving through HHS’s 2026 Unified Agenda, with formal rulemaking expected in 2027. It would kill the “adequate provision” option broadcast ads have relied on since 1997, meaning ads would need to fit the full side-effect summary into the airtime itself. HHS and FDA have both said that would make most broadcast ads a thing of the past.^2,3 

Enforcement isn’t waiting on the rule. FDA sent almost no untitled letters in 2023 or 2024, then roughly 40 in one wave in September 2025, plus about 100 cease-and-desist letters.^4,5 That pace has continued into 2026, hitting major immunology and rare disease brands especially hard. 

In a recent industry survey, DTC regulation ranked as the trend most likely to reshape pharma marketing this year, ahead of AI.⁶ Broadcast dollars are already moving, and the brands paying attention are using this window to rethink the holistic patient education and engagement journey.⁷ 

And the case for examining the patient journey doesn’t rest on regulation alone. Patient education improves adherence, cuts hospitalizations, and helps patients walk into treatment conversations with more confidence.⁸ Budget that’s been locked into 30 seconds of airtime can go toward something patients retain with measurable impact.  

Medlive Patient: A Unique Model that brands are already leveraging 

Many of us who have worked in pharma recognize there is a trust gap. Patients trust the advocacy group that’s been in their corner for years.  

That’s why Medlive built its patient education model in alignment with more than 100 advocacy partners spanning rare disease, immunology, oncology, neurology, cardiology, and more.  

 These partnerships have driven strong results for our pharma clients. Consider the engagement we’ve seen with Medlive Engage for Patients: 18 minutes average time in-session, 152 live questions asked per program, 106 Q-board/polling interactions, over 1,200 video views per program.  

It’s impossible to replicate the behavioral impact of 18 minutes of content with a 30-second TV ad. 

Regulatory pressure isn’t going away. What matters is what brands do next. 

If you’re planning 2027 right now, let’s talk about where education fits into it. 

References 

1. “Prescription Drugs: Medicare Spending on Drugs with Direct-to-Consumer Advertising.” United States Government Accountability Office, May 2021.
2. Foley Hoag LLP. “FDA Proposes to Eliminate ‘Adequate Provision’ for Broadcast Prescription Drug Advertising.” July 2026.
3. Latham & Watkins LLP. “FDA Proposes to Eliminate ‘Adequate Provision’ Standard for DTC Broadcast Advertising.” July 2026.
4. Covington & Burling LLP. “FDA Advertising and Promotion Enforcement Activities: Update.” April 2026.
5. U.S. Food and Drug Administration. “FDA Launches Crackdown on Deceptive Drug Advertising.” FDA.gov, September 9, 2025.
6. Health Union. “Pharma Marketers Pulse Report: 2026 Key Findings.” February 2026.
7. Fierce Pharma. “2026 Forecast: Pharma Ad Dollars Will Continue Shifting Away from Traditional TV.” December 2025.
8. Alhassoon, Fahad, Bushra Saleh, et al. “The Effectiveness of Patient Education in Improving Health Outcomes.” Journal of Population Therapeutics and Clinical Pharmacology, vol. 29, no. 4, 2022, pp. 2174-2179.