Facebook notified pharma companies that, as of August 15, they could no longer disable the comments functionality on their Facebook pages. Pharma has had the best of both worlds - a degree of participation in the largest social network without the risks associated with conversing with patients. Facebook concluded, however, that this carve-out did not support "authentic dialogue between people and businesses."
Marketers using Facebook know complaints might be posted about the brand. Pharma has this and other concerns about potential action if people post inaccurate information, discuss off-label use of therapies, or mention unwanted side-effects. Marketers wonder if the risks, which could spur regulatory action, outweigh the benefits of connecting with customers.
They can't consult FDA guidance on social network use as it's overdue. How, then, to proceed? Some have deleted their pages, but others have calculated they can't afford not to be on the ultra-popular Facebook. What steps should companies take to stay?
- Evaluate whether the policy applies to them. Facebook may still make exceptions for pages dedicated to prescription drugs.
- Some companies run Facebook pages for broader patient communities. They might want to shift their focus toward a brand.
- Use software that takes the place of Facebook Wall functionality to review comments before posting.
Marketers who want to stick with native Facebook functionality and converse with people must do more work, but may benefit from genuine engagement.
- Monitor their Facebook page several times a day.
- Have a response matrix, created with legal and regulatory colleagues, to ensure a consistent approach to replying to, moderating or deleting comments, or escalating them in the unlikely event they must be reported to the FDA.
- Consider having a member of their medical staff reply to questions from patients.
- Create quality content that people want to respond to or share. Even if someone "likes" a page, Facebook's EdgeRank formula means the content is less likely to be displayed in news feeds if no one's interacting with it.
The recent changes put the onus on pharma companies to engage fully. If the objective is an idea exchange with customers, up-dates to Facebook might make it well worth that commitment.
Laura Kempke is SVP and head of the content marketing practice at Schwartz MSL.