Prescription drug direct-to-consumer advertising (DTCA) has been a subject of controversy in recent years. Though government regulations require equivalent prominence of risks and benefits, there is concern about the ability of consumers with limited health literacy to fully comprehend the risks and benefits associated with drug use. Evaluating the images in DTCA is important because individuals may rely on the visual message if the wording is overly complex. Using semiotics, this study aims to evaluate whether there is functional equivalence in the presentation of risk and benefit information in prescription drug direct-to-consumer television advertising. A new analytical method is created and used to assess the consistency between the messages contained in the voice track, the primary visual images, and the superscript/ subscript text. The results indicate that risk and benefit messages in this DTCA sample lack functional equivalence. However, it is important to properly frame these findings as the study does not evaluate viewer comprehension of the various message structures.