Marketing in a MAHA World: Four Ways Creativity Breaks Through

With the release of the Make America Healthy Again report and the FDA’s sweeping September 9 crackdown on pharmaceutical advertising, pharma marketers are facing a new era of scrutiny. The FDA’s enforcement wave included cautionary letters and cease-and-desist notices targeting direct-to-consumer (DTC) ads — not just on TV, but across influencers, telehealth, digital platforms and even search. 

Violations ranged from omitted safety risks to misleading equivalency claims, signaling a broader regulatory net that now includes social media and non-traditional promotional channels. But amid this heightened oversight, creativity does not have to retreat.  

These four campaigns prove that pharma marketers can still break through, creatively and compliantly, while avoiding the new regulatory fault lines the FDA has drawn. 

1. Ask for Clear: Unbranded That Moves the Needle 
   Novartis’s UK-based unbranded campaign, Ask for Clear, cleverly nods to COSENTYX’s endpoint of “skin clearance,” a savvy choice under today’s regulatory pressures. In today’s climate, where branded TV is increasingly cost-prohibitive due to extended major statements, unbranded campaigns offer a nimble alternative. This effort was quirky, memorable and impossible to ignore. By driving patients to “ask for clear,” the work seeded conversations with HCPs that naturally led to a COSENTYX prescription, showing how unbranded can still support brand uptake. 

2. Test Your Genes: Diagnostic Activation That Expands the Market 
   Johnson & Johnson’s Test Your Genes initiative is a standout example of unbranded education that leads to measurable behavior change. By spotlighting the link between BRCA mutations and increased prostate cancer risk in men, the campaign didn’t just raise awareness, it drove a 5% national increase in BRCA testing rates, with an impressive 24.4% engagement rate. 
   
   This diagnostic-first approach empowered men to take proactive steps through genetic testing, naturally setting the stage for more informed treatment conversations—where AKEEGA, J&J’s therapy indicated for BRCA-mutated prostate cancer, becomes a relevant option. Importantly, the campaign remained fully compliant with FDA guidance by steering clear of any unapproved prevention or treatment claims. Instead, it focused on activating diagnostic awareness, laying the groundwork for brand relevance without compromising regulatory integrity. 

3. Lil Miquela: The Rise of Virtual Influencers 
   Lil Miquela, a computer-generated influencer with over 2.4 million Instagram followers, generates more than $10 million annually through partnerships with brands like Prada and Calvin Klein. While not a pharmaceutical campaign, her success offers valuable insights for our industry: she exemplifies the impact of consistent storytelling, complete message control and the ability to bypass the unpredictability of human celebrities. 
   
   Pharma has begun exploring digital twin KOLs, but Lil Miquela demonstrates the full potential of scalable virtual personas. To succeed, these avatars must still navigate the complexities of social media algorithms. In a highly regulated space like ours, where compliance and risk management are non-negotiable, virtual influencers could represent a future where brand engagement is both innovative and compliant. 

4.  A Touch of Flu: Experiential Marketing That Resonates 
   The experiential installation A Touch of Flu brought the burden of seasonal illness to life, literally, by allowing passersby to “feel” its impact. Rather than promoting product performance, the activation sparked cultural conversation and created a sense of urgency. This approach stands in sharp contrast to the kind of unauthorized claims and misleading messaging recently flagged by the FDA. 
   
   For pharma, experiential activations offer a powerful way to build emotional resonance, generate earned media and amplify reach across digital platforms, all while staying firmly within compliance boundaries. By avoiding risk omission and unsubstantiated promises, they demonstrate how creativity and regulatory responsibility can coexist. 

In a post-MAHA landscape, where regulatory scrutiny is intensifying and the FDA is expanding its reach across digital and non-traditional channels, pharma marketers face a pivotal moment. But as these four campaigns illustrate, compliance does not have to come at the expense of creativity.  

By embracing unbranded storytelling, virtual innovation and emotionally resonant experiences, pharma marketers can navigate the new rules while still driving meaningful engagement. The path forward is not about playing it safe; it’s about playing it smart.