Facebook, Pharma, and the Potential for Open Comments

April 28, 2011

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Recently, word began circulating that Facebook has plans to enable comments on all fan pages. This news has taken many brands in regulated industries (e.g. pharma, finance) by surprise. Until now, the majority of pharma companies that have embraced Facebook have done so solely because they could disable the comments option on their fan pages. Rumor has it this new policy will take effect early this summer.

So what does this mean for pharma? Well, we're certain for many healthcare companies, brand managers, and communications people contemplating a Facebook presence, their battle with the legal and regulatory folks may have just gotten a bit harder.

Our understanding from the information coming out of the DTC national conference is there are three exceptions to the planned revised policy:

  • Pages that promote, talk about, or support prescription drugs or devices
  • Pages that focus on a disease state where there is only one prescribed treatment (even if the Page doesn't mention the treatment)
  • Disease-state/therapeutic area Pages that have the PI/ISI on the Page

Pharmaceutical and device companies have been waiting on the social media sidelines for the FDA to issue official guidance on how they can play in this space and the few that have taken the plunge have mainly done so with unbranded efforts or a corporate presence. With this change in the Facebook landscape, it will be interesting to see how many stay engaged in unbranded/disease awareness pages and how this impacts their marketing efforts moving forward.

For pharma corporate pages that have disabled the commenting option, we'll be watching to see how they emerge and if this change means some will disappear or if they will embrace the opportunity to communicate with their audiences.

We recently pulled examples of existing Facebook pages for a pharma client considering adding Facebook to an existing unbranded campaign. Of the five or so examples we shared with the client, three of them allowed comments already and the other two fit into the exception category.

So maybe this won't be such a big deal? What are you hearing about this change? Have you heard this change is coming? Will companies and brand teams have the commitment to monitor their presence and the foresight to plan ahead for the possibilities, both good and bad?

The good news is there are tools you can build to mitigate the risk of your wall being populated with specific drug-related posts, spam, off-label use, disgruntled employees or aggressive competitors. Clients can build in a custom application that integrates posts similarly as the regular wall but provides additional control to the page admin. Pages like Boehringer Ingelheim (BI),  AstraZeneca U.S. Community Connections (AZ) and Sanofi-Aventis U.S. Diabetes (SA) are good examples of the the options currently being implemented from a regular Facebook wall with a specific posting policy (BI) to custom wall  applications (AZ and SA). However, if this Facebook rumor about open commenting becomes a reality, even brands with custom commenting apps will still have the standard Facebook wall with which to deal.

As for our client considering Facebook, we'll see what happens. Their regulatory group has traditionally been very conservative and not being able to turn off the comments will, most-likely, be a deal breaker for them. That said, the first step is education — We're working to help our contacts and their regulatory reviewers understand this change, the options available to them, and the most strategic next steps to achieve the results they desire.

How will you be tackling this potential change?