Pharmaceutical marketers are stuck between a rock and a hard place when it comes to social media -- they are trying hard to embrace it, but the very nature of the two-way dialogue endemic to the medium threatens to work against them. Case in point: Facebook's new policy that will no longer allow drug makers to disable the comments feature on their pages.
Being forced to enable comments on its Facebook pages puts pharmaceutical companies at risk of running afoul of the current Food and Drug Administration regulations, even if it's only consumers making the comments. For instance, if a company has a branded page for an antacid, and a consumer comments that it helped lower his blood pressure as well, that 's considered off-label promotion and the FDA could conceivably send a warning letter to the company. Some companies are concerned even though Facebook said it will consider allowing the comment function to be removed for branded drug pages, where it is more likely those kinds of comments will turn up.
"This kind of hurts us," said a digital-strategy chief at one of the top 10 pharma companies regarding the new policy, which takes effect Aug. 15. "In large part, having a Facebook page gets us in the social media door and not having comments keeps us in good graces with FDA. "
"We're standing on the sideline of a nice fight between two 800-pound gorillas," said Jim Dayton, senior director of emerging media for Overland Park, Kan.-based InTouch Solutions, a pharma-centric digital-marketing agency. Mr. Dayton and InTouch received a copy of the letter Facebook sent to pharma companies, and posted the missive on its site.
"I'm reaching out to inform you of a policy change regarding pharma pages on Facebook that may affect one or more of your brand pages," it reads. "As you know, Facebook pages are a free product for organizations, public figures, businesses and brands to express themselves and have an authentic, engaging, two-way dialogue with people on Facebook. 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. ... Subject to Facebook's approval, branded pages solely dedicated to a prescription drug may [continue to] have commenting functionality removed."
The letter continues: "We think these policy changes support consistency for the Facebook Pages product and encourage an authentic dialogue between people and businesses on Facebook. However, we also understand that these changes may lead you to re-evaluate your strategy and presence on Facebook. We are committed to helping you during this transition."
Former FDA associate commissioner Peter Pitts, now the president of the Center for Medicine in the Public Interest, said the FDA has made it clear that it is not going to issue platform-specific guidance on social media, so drug makers shouldn't sit around and wait.
"The Facebook decision is entirely consistent with what Facebook is designed to be -- interactive. A Facebook page with the interactivity turned off is just a static web page residing on an interactive platform. And that isn't what Facebook is all about," Mr. Pitts said. "It's time for regulated industry to step up to the plate and embrace the powerful tool that is real-time interactivity."
Jonathan Richman, group director-insights and planning for Cincinnati-based agency Possible Worldwide, said some pharma companies already have comments enabled on their Facebook pages and it has yet to result in an FDA warning letter. "How much risk do the comments others leave on your posts incur? I'd argue that they produce very little risk," he said. "If someone posts something inappropriate, you still have the ability to delete it. But there will be some panic about this among pharma companies. Some will take down their pages completely."
And some with good reason, according to the digital-strategy chief, who said the industry is concerned that comments could include attacks on the company and outright misinformation. "Unless we can come to some sort of agreement with Facebook on the whole comments thing, it basically comes down to every pharma [company] having to decide whether Facebook is going to be part of their marketing. I don't see a gray area."
A Facebook spokeswoman said that the company does not comment on conversations with clients. But its official statement indicates some wiggle room. "In an effort to encourage conversations between brands and people, we recently made some changes to our policies that affect some official pharmaceutical pages directed at building communities. This change does not affect pages for prescription drugs. We think these changes will help encourage an authentic dialogue on pages."
And with social media expanding every day and Facebook offering access to half a billion people, it's a gamble drug makers might have to take. "I don't think pharma will abandon Facebook," said Mike Guarini, president of ad agency Ryan True Health, Wilton, Conn., and a former pharmaceutical-company ad exec with Bristol-Myers Squibb. "I think pharma will proceed more deliberately with social media, but they won't abandon it."
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