
Winston Francois builds programmatic media programs that survive MLR review, work inside Meta and Google's pharma advertising restrictions, and still reach a real patient or HCP population, including populations measured in the hundreds. We embed as your fractional media team, not an agency running someone else's playbook.
The Health-Data Segments You Want to Buy Don't Survive Legal Review
Third-party data brokers sell condition-based audience segments, diabetes, oncology, cardiovascular, built from opaque consent chains that most in-house counsel will not sign off on once HIPAA and state health-privacy law get involved. Media buyers show up with a segment list and legal sends back a rejection with no alternative. The team ends up buying broad demographic proxies instead, which spend the same budget against a much less relevant audience.
Brand Safety Blocklists Remove the Exact Content Your Audience Reads
Standard brand safety keyword lists block terms like cancer, diagnosis, and depression to avoid adjacency to distressing content, which also blocks the news articles, patient forums, and condition-specific content your actual target audience is reading. Turn the blocklist off and you sit next to adverse-event reporting, competitor drug controversy, or an unrelated recall story. Most programmatic teams pick one problem or the other because nobody has built a pharma-specific safety taxonomy instead of a generic one.
Fair Balance and ISI Do Not Fit in a 300×250 Banner
Every branded promotional unit needs risk information alongside the benefit claim, and a standard display or pre-roll unit was never designed to hold both. Creative teams default to a companion unit or a click-through ISI page, and most DSPs and ad servers treat that as a bolt-on rather than a first-class part of the ad unit. When MLR flags the workaround during review, the whole flight slips because there is no pre-approved format to fall back to.
Meta and Google Restrict the Categories You Need Most
Branded prescription drug advertising requires platform certification on both Google and Meta, and even certified accounts face restrictions on condition-based interest targeting that would be routine for a consumer brand. Unbranded disease-awareness campaigns get flagged as branded by automated review more often than teams expect. The result is that a meaningful share of paid social and search reach is simply unavailable, and budget gets pushed into open exchange inventory with weaker targeting precision and more fraud exposure.
Rare Disease Populations Are Too Small for Standard Programmatic Math
A rare disease patient population might be a few thousand people nationally, and the prescribing specialist population might be a few hundred physicians. Most DSP audience tools assume a minimum viable segment size in the tens of thousands before lookalike modeling or frequency optimization does anything useful. Below that threshold, algorithmic optimization has nothing to learn from, and campaigns either burn budget on an audience too broad to matter or sit dormant because the platform cannot find enough matches to spend against.
Attribution Falls Apart the Moment Reach Splits Across Channels
A real pharma media plan spans CTV, open exchange display, restricted social inventory, and direct HCP portal placements, and none of those environments share an identity graph. Nobody can connect an impression to a prescription lift, a sample request, or an HCP portal visit without stitching four incompatible reporting systems by hand. By the time an MLR-approved measurement plan gets cleared, the campaign that plan was supposed to measure has already finished running.
We start with a two-week audit of your current programmatic setup, not a generic media audit.
From there we rebuild the audience architecture around what you can actually defend.
On the creative side, we work directly with your MLR and regulatory teams to design modular ad units with fair balance and ISI built in from the start, expandable units, native placements with a persistent ISI footer, CTV companion frames, so the format is pre-approved once instead of re-litigated every time the media plan changes.
For walled gardens, we manage the Meta and Google pharma advertising certification process directly and build campaign structures that stay inside each platform's condition-targeting restrictions without losing relevance, using contextual and first-party signals in place of the interest categories that get flagged.
For rare disease programs, we do not force a population of a few thousand patients through algorithmic optimization built for mass-market scale.
On measurement, we build a single reporting pipeline that stitches CTV, open exchange, and walled garden data before the flight launches, with the measurement plan cleared by MLR ahead of go-live instead of after.
We work fractional and embedded, not project-and-disappear. The person negotiating your Meta pharma certification is the same person your MLR team emails when a creative question comes up three weeks into the flight.
The programmatic tactics that work for a consumer DTC brand actively hurt you in biotech and pharma. The walled garden restrictions, the fair balance requirements, and the population math on rare disease all need a different model built for this category, not a scaled-down version of a playbook built for skincare.
We run in 90-day sprints because that is enough time to rebuild a real programmatic program without locking you into assumptions that go stale. Days 1-15 are the audit: DSP setup, current segments, brand safety configuration, MLR cycle time, and walled garden certification status. Days 16-45 are the rebuild: new audience architecture, pre-approved creative formats, and platform certification work running in parallel with your compliance team. Days 46-75 are live flight and instrumentation, tested against real campaigns rather than a staging environment. Days 76-90 are handoff and documentation, including the measurement plan MLR needs to sign off on for the next flight.
This is different from a traditional media agency in one specific way: we do not hand you a media plan deck and hand off execution to a trading desk that has never sat in a room with your regulatory team. We build the audience architecture and creative templates directly with your MLR and legal teams in the loop from day one, because a targeting approach your compliance team rejects in week twelve is worse than no targeting approach at all.
The first 30 days are diagnostic. We embed with your marketing, legal, and regulatory teams to map the current programmatic setup and come back with a prioritized rebuild plan, not a slide deck ranking problems nobody has time to fix.
Days 31-60 are build and certification. We are inside your DSP and ad server configuring the new audience architecture and creative templates while walled garden certification runs in parallel, since that approval process often takes longer than the media build itself.
By day 90 you have a live, MLR-cleared program running, not a plan for one. From there we typically stay on as a fractional media team, weekly cadence during active flights and biweekly once the program stabilizes, with direct access to the people who built it rather than a rotating account team.
If your biotech or pharma company needs a programmatic advertising program that actually clears review, we should talk.
If your biotech & pharma company needs programmatic advertising leadership, we should talk.

Let us take a custom approach to your growth goals by assembling and leading the best-in-class marketing team to support your next stage.
We build audience segments from first-party CRM data and consent-documented sources instead of third-party health-data brokers whose consent chains cannot be verified. HCP targeting typically runs through firmographic and specialty data rather than any patient-level signal, and patient-facing campaigns lean on contextual and demographic targeting rather than condition-based segments pulled from opaque data sets.
Yes, that certification process is one of the most common things we manage directly. Branded prescription drug campaigns need platform-level certification on both Meta and Google, and unbranded disease-awareness campaigns often need extra documentation to avoid getting flagged as branded by automated review.
We design modular ad formats with your MLR and regulatory teams before any media buying starts, expandable banners, native units with a persistent ISI footer, and CTV companion frames built specifically to hold risk information alongside the benefit claim. Getting the format pre-approved once means your media team is not re-litigating the same compliance question every time the plan changes.
It can work, but not with a standard media plan built for mass-market scale. When the addressable population is a few thousand patients or a few hundred specialists, we build a smaller, manually curated plan instead of relying on algorithmic optimization that needs a much larger data set to learn from.
We build the creative approval process in parallel with the media plan instead of sequentially, so MLR is reviewing pre-approved modular formats rather than a brand-new ad unit every flight. We also get the measurement plan cleared before launch, not after the campaign has already run, which is usually where teams lose the most time.
Engagements are scoped fractional, typically in the range of $12K-$30K per month depending on media spend under management and how much certification and creative rebuild work is involved up front. That covers the embedded team managing the program, not a fixed set of deliverables, since the highest-value work in the first 90 days is usually the audience and creative rebuild rather than the media buying itself.
We build one reporting pipeline that stitches CTV, open exchange, and walled garden data into a single view before the campaign launches, rather than trying to reconcile four incompatible platforms after the fact. Because walled gardens will not share user-level data, the model relies on aggregate lift and channel-level performance rather than a single cross-platform identity graph, and we are upfront about that limitation instead of presenting a stitched number as more precise than it is.
Tuesday, June 16, 2026
Frank Growth – Episode 224 – The Bootstrapper’s Revenge with Alex Roy
Tuesday, July 21, 2026
Frank Growth – Episode 229 – Longevity Medicine’s Dirty Secret with Jim Donnelly
Tuesday, September 1, 2026
Frank Growth – Episode 235 – The Marketing Engineer with Nick Lafferty
Tuesday, August 25, 2026
Frank Growth – Episode 234 – Nobody Has The Playbook Yet with Dave Steer
Ready to unlock your growth?
Book Free Call