PharmaWall Lets Pharma and Facebook Still be Friends
As most people in pharma marketing circles know by now, Facebook officially announced changes to their commenting policies on Facebook Pages with the following communication:
"Previously, pharmaceutical brands could submit a request through their Facebook Sales Representative to disable commenting on their Facebook Page. Starting today, Facebook will no longer allow admins of new pharma Pages to disable commenting on the content their Page shares with people on Facebook. Pages that currently have commenting disabled will no longer have this entitlement after August 15th. Subject to Facebook’s approval, branded Pages solely dedicated to a prescription drug may (continue to) have commenting functionality removed". (this is a portion of the full communication; reprinted with permission)
Pharma companies -- especially those in the U.S. -- relied on this option to disable comments as a way to engage on Facebook in a more controlled manner. It was one of the few ways companies could have a presence, yet remain mindful of the risks of two-way, open dialogue in this highly regulated space.
[NOTE: If you’re new to this issue or need a refresher, see my previous ePharmaRx blog post and the original post from Jim Dayton on intouchsol.com. It’s also been written up by ClickZ, Dose of Digital, MMandM, Advertising Age, InsideFacebook, and many others.]
In a Perfect World ...
Where does this leave the product managers, communications managers, and the agencies that support them that have — or have in progress — pharma Facebook pages? Well, in a perfect world …
- In a perfect world, a pharma brand wouldn’t approach Facebook or social media any differently than other industries.
- In a perfect world, pharma would embrace social media as a way to connect at a personal level with a patient population that often sees Big Bad Pharma as a faceless, inhuman, profiteering enemy.
- In a perfect world, pharma would embrace Facebook as a place to provide help, hope, and support on products and conditions where millions of people dwell every day.
- In a perfect world, consumers would understand FDA/DDMAC rules and regulations and would not post anything off-label — whether positive or negative — on a pharma Facebook page.
Obviously our world is far from perfect. And the wrath of FDA is very real. There are many people whose job is to keep their pharma company from getting a warning letter. And to those people … open, unmoderated discussions in a forum such as Facebook often just simply are not worth the risk.
What’s the Big Deal?
I live and market in the U.S. where the industry is heavily regulated by a warning-letter-happy FDA. Pharma legal and regulatory folks’ concern around open forums like Facebook are many, and they are valid. They worry that users will mention off-label uses for the product, make unsubstantiated positive (“this drug cured me!”) or negative (“this drug sucks!”) claims, attack or harass the company, talk about unrelated symptoms, mention side effects, or provide misinformation via their Facebook Page. With commenting enabled on all Facebook Pages, users can now openly engage in this activity. It is probably unlikely, but even a 1% likelihood is what keeps the regulatory and legal folks up at night. And thanks to FDA’s lack of guidance on the subject, it’s unclear whether a pharma company is liable for this user-generated content or not.
There are a number of options available for pharma companies still interested in engaging on Facebook. And I’d maintain that if they were interested in Facebook before the policy change, these options or a combination of these options will absolutely still allow them to safely maintain a Facebook presence. Jim Dayton did a great review of options for pharma companies wishing to use Facebook, and I’d recommend you read his post. Among them,
- Moderation applications - a solid option for some; more on this in a bit ...
- 24/7 monitoring and moderation - also a great option if you have the resources. Around-the-clock moderation allows for the best of both worlds: real-time conversations and well-trained eyes watching for violative content. However, few pharma companies are setup or are dedicated enough to do this
- Branded Facebook pages - there aren’t many of these now, and some might ask, "what’s the point" if dialogue isn’t allowed
- Personal representation - similar to a trained media spokesperson, some have had success with this model
- Advertising - though not truly "social," it’s a controlled way for pharma to have a presence and get the word out where they need to. (No, Facebook didn’t pay me to say that.)
Page owners can also create a list of words that Facebook will block if contained within a comment. For example, on an unbranded page, if someone mentions the product name or the word “cure,” you can set up Facebook so that it automatically holds these comments for later review. But this feature in Facebook can’t detect sarcasm, can’t interpret tone, and can’t always account for “mis$pelling$ and other trix” people use to post what they want. If they’re determined, they will find a way to get past your filter. And if they are successful, their post will go live immediately and you’ve exposed yourself to risk. In our experience this feature helps a little, but it’s far from foolproof. And it’s not failsafe enough for the folks responsible for keeping their company from getting a warning letter.
PharmaWall’s Pharma-Friendly Features
But back to the first option: moderation applications. For pharma companies that choose this option, my agency, Intouch Solutions, has a Facebook monitoring and moderation tool called PharmaWall. Here’s how it works:
- A user submits a post or comment (“content”) to the Facebook page. Expectations are then set with the user that their post or comment is being sent for review.
- PharmaWall detects the content and notifies a designated administrator.
- The administrator reviews the content in the queue and decides whether it will be approved, revised or declined
- If the content is approved, it publishes to the Facebook page.
- Copies of all content—as well as decisions to approve, revise or decline—are documented for later review.
People can still “like,” post, and comment on your Facebook content. Their “likes” and comments are shared with their friends, too. PharmaWall also still allows the display of messages in the news feeds of all Facebook members who have “liked” the page, keeping them up-to-date on your latest news and information. There’s just an added safety net for pharma’s peace of mind.
We’ve mentioned PharmaWall in a few places before today. We’ve had the app live on several Facebook Pages for some time. But knowing that the August 15 deadline is looming and companies and their agencies are clamoring for options on what to do, we wanted to get the word out about PharmaWall as an option.
So we we launched a little website about the product, www.thepharmawall.com, including a video that takes you through the functionality. And we built an unbranded demo on Facebook for a fake condition called "LowEnergy." Give it a “Like” and take it for a spin. If you want to see the Admin side, you can request a demo. If you’re interested in speaking with someone about PharmaWall or our monitoring/moderation services, just let me know.
Love it or hate it, the combination of the current environments of both Facebook and FDA make apps like PharmaWall a viable option for pharmas that want to meet in the middle between regulation and engagement.
It’s (Almost) August 15 — Do you Have a Plan?
Pharma marketing/advertising development and review cycles are kind of like dog years. What one might expect should take weeks to develop/approve can take months. This makes Facebook’s August 15 deadline even closer. Do you have a Facebook Page live or in development? And if you do … does your Facebook Page have a plan?
Whether you decide a moderation application, 24/7 monitoring, creating a ’blocklist’ or a combination of solutions is right for you, wheels should be set in motion now.