Pharma content cost: agency hours per approved asset
Veeva data says nearly 80% of approved pharma content is rarely or never used. How to measure cost per approved and per used asset without touching compliance.
Regulated marketing teams know their content is expensive. Few can say what an approved asset costs, how many agency hours went into it, or how many of those assets anyone used. Those numbers can be measured without touching a single compliance decision, and they are where the money is.
Volume keeps rising
FDA's Office of Prescription Drug Promotion gives a rough measure of how much material companies produce. OPDP reported receiving more than 64,000 Form FDA 2253 submissions in 2022, covering more than 140,000 individual promotional communications. By 2024 it was more than 70,000 submissions and more than 150,000 pieces, up 7.9% on the year before. That is only prescription drug material that reaches the agency. It excludes internal training, most localization and consumer health work outside FDA's prescription drug remit.
Veeva's 2022 content benchmark, built from data across 350 pharma companies, showed the average company approving 1,102 assets a quarter at the end of 2020 and 1,508 by the end of 2021. Digital content ran at 3.3 times the volume of print. Average time from creation to approval was about 21 days, with 1.4 review cycles per piece.
Most of it never gets used
This is the uncomfortable number. In May 2025, Veeva reported from its field data that nearly 80% of approved content is rarely or never used, and that field teams use content in fewer than half of HCP meetings.
Every one of those unused assets was briefed, written, designed, reviewed by medical, legal and regulatory, revised and approved. The agency billed for it. MLR spent hours on it. If four out of five pieces sit in the library, the cost per used asset is roughly five times the cost per approved asset. Nobody puts that number in a budget review.
Variants are where agency hours hide
Most of the volume is not new ideas. It is variants: the same core claim recut for email, banner, rep-triggered email, social, the HCP site, the patient site, three audiences, two lengths and every market that localizes. Each variant gets billed. Many get reviewed as if they were new.
Rules add more. FDA's final rule on the major statement in DTC TV and radio ads was published in November 2023, with a compliance date of November 20, 2024. It applied to every DTC TV ad still in circulation on that date, and its dual modality requirement means the major statement has to appear in text on screen as well as audio. Spots that did not meet it had to be recut. Then in September 2025, FDA and HHS announced a crackdown on DTC advertising, with about 100 cease-and-desist letters and a templated letter to thousands of companies. King and Spalding counted 74 letters to manufacturers in 2025, 42 of them on DTC television ads, the highest annual total in nearly 25 years. Every finding triggers revisions across all versions of the affected material.
Consumer health is not exempt. The FTC's Health Products Compliance Guidance, issued in December 2022, says health claims generally need randomized controlled human trials as substantiation, and names ad agencies among the parties that can be liable. Lighter review than prescription drugs, still real review, still billed hours.
Modular content changes the unit price, if you let it
Modular content means approving claims and content blocks once, then assembling them into many formats. Veeva said in 2023 that eight of the top ten biopharmas use its PromoMats modular content features. It also reported customer results: one cut time to market by more than 50% with 40% more reuse and 30% faster approvals, and another reached 75% single-cycle approvals with costs down 19%. These are vendor-reported, customer-selected examples, not an industry average. IQVIA makes the same economic argument: the savings come from reuse and lower agency spend.
The catch is commercial. If the agency's rate card still prices each assembled variant like a new piece of creative, modular content saves review time and nothing else. Pfizer's model shows the other direction: Campaign reported that when Pfizer moved global creative to Publicis in early 2024, Publicis already handled its data, media and production. Separating production from creative gives a buyer a way to price assembly as assembly.
How to measure it without touching compliance
The data you need already exists in your review system and agency invoices. Nothing here changes who reviews what, or the standard they apply. It is read-only.
- Cost per approved asset, by type. Agency fees and production cost for the period, divided by approved assets, split by format: DTC video, HCP email, banner, detail aid, social, web.
- Agency hours per approved asset. Ask the agency for hours by job number. Map job numbers to asset IDs in the review system.
- Variants per master. How many approved pieces derive from each core concept. High counts are fine if variants are priced as assembly.
- Review rounds per asset and why. Tag each revision round by cause: brief changed, agency error, MLR comment, new regulatory requirement. Only the last two belong to compliance. The first two belong to marketing and the agency.
- Usage rate. Share of approved assets used at least once in the field or in market in the following 90 days.
- Cost per used asset. The number that tells you what the library costs.
Run it for one brand over two quarters. The patterns show up fast: one format eating most of the hours, one cause driving most of the rework, a block of assets nobody touched.
What to put in the agency contract
Once you have the baseline, write it into the scope:
- A rate card by asset type, with separate, lower prices for assembling approved modules and for localizing.
- A defined number of revision rounds included, with rework caused by agency error at the agency's cost and rework caused by brief changes visible as its own line.
- Hours reported by job and asset ID every month, so the measurement keeps itself current.
- A usage review each quarter that retires assets nobody uses and stops briefing new variants of them.
Our earlier piece on the MLR review tax covers the process side. This is the commercial side of the same problem.
The next step
Pull last quarter's approved asset list for one brand and the agency invoices for the same period, and calculate cost per approved asset and cost per used asset. If the second number is more than double the first, the library is the place to start. Our pharma and consumer health work and the Diagnostic run that analysis across brands and agencies.
Sources: FDA OPDP, The Brief Summary, January 2023, FDA OPDP, The Brief Summary, January 2025, Veeva, 2022 Content Metrics Global Trend Report, Veeva, Veeva Pulse report finds content-driven engagement lags, Arnold and Porter, Requirements for DTC TV and radio prescription drug advertising, King and Spalding, HHS and FDA declare crackdown on drug advertising and promotion, King and Spalding, 2025 year in review: FDA drug and device advertising and promotion enforcement, Covington, FTC issues new guidance on health-related claims, Veeva, Modular content powers omnichannel engagement at speed and scale, IQVIA, Customer engagement starts with a single building block, Campaign, Pfizer moves creative from IPG to Publicis after just 10 months.
How much approved pharma marketing content actually gets used?
Veeva reported in 2025 that nearly 80% of approved content is rarely or never used, and that field teams use content in fewer than half of HCP meetings.
How do you measure the cost of regulated marketing content?
Divide agency and production cost by approved assets for each format, then by assets actually used. Add review rounds per asset tagged by cause, so rework from brief changes and agency errors is separated from compliance-driven changes.
Does modular content reduce agency costs?
Only if the contract prices assembled variants below new creative. Veeva customers have reported faster approvals and lower costs, but if the rate card still bills every variant as a new piece, the saving stays with the agency.
We would rather look at your numbers than talk about ours. Fifteen minutes is enough for us to tell you whether your agency terms are worth reopening before 2027 budgets lock.