What this means: Up until now, pharma companies with Facebook Pages could request that Facebook disable the ability for people to comment on and/or Like brand posts. This exception should not be confused with the ability every Page has to disable the capability for fans to originate a post. Even where Pages do not allow fans to post, people can comment on the Page owner’s posts (unless they have requested and received such an exception). You can read a really good explanation of the difference at Jonathan Richman’s Dose of Digital site.
The only Pages still eligible to request a commenting exception are branded Pages for prescription drugs or non-branded Pages centered on a disease state for which only one prescribed treatment exists. As of August 15, 2011, other Facebook Pages (even those previously eligible for exception — such as disease state Pages and OTC product Pages, like NyQuil) will see the comment and Like capabilities appear for fans.
Planning for interaction
For those companies who’ve had comments disabled to this point, and who’re no longer eligible for the exception, it’s essential to be prepared for the change. The truth is that, given FDA regulations, companies will need either to put well-planned Facebook moderation in place, or terminate their Pages. Because of the obligation to report adverse events (untoward experiences people have with a pharma product), certainly there’s no option not to moderate.
For all pharma companies planning to run Facebook Pages around OTC products or disease states, the resources required for running a Page are now quite different. It will no longer be enough to simply publish information to the Wall — a glorified digital brochure, really. Instead, companies need to be thinking about moderation of undesirable content like spam and profanity, about dealing with comments describing adverse events or off-label use, and ideally, about providing knowledgeable brand representatives who engage in a meaningful, helpful way with people who comment on their Pages.
At LiveWorld, we’ve been thinking about best practices for pharma for some time. Online venues are now and increasingly will be a major source of health information, sharing of experience, and support. This is a very good thing for a number of reasons: It’s good for people to be able to talk with each other about their experience living with health issues. It’s good for pharma and healthcare providers to hear from the people who are using their products. It’s good for people to get reliable information from experts.
While it’s understandable that pharma companies are nervous about the legal implications of people talking about their products, it’s also a great opportunity. Pharma can support all the potentially positive dynamics by allowing people to benefit from the company’s considerable knowledge base, by responding to users who bring forward issues and questions, and by providing a venue for connection among people who use their products and may be dealing with similar life experiences. Plus, they’ll learn a lot from their customers.
People will always talk
Regardless of whether pharma companies decide to keep their Facebook Pages, people will find places to talk to each other about their experiences with particular products and disease states. If companies hold back on providing such conversational venues because of fear of legal liability, the public loses benefits the company can offer, and the company loses the benefit of a close relationship with their customers. When issues and questions come forward on the Page a company owns and controls, at least there’s the possibility of being able to respond, correct, or connect with the commenters. It’s much harder to take such positive actions on comments posted on any of the thousands of possible venues across the social web.
Best practice for pharma
Understanding that any pharma company has to decide how much risk it can take with the FDA — which hasn’t yet clarified its stance on legal liability of companies in online venues — we recommend companies keep their Facebook Pages open, invest further in them, and provide diligent moderation of comments from the public. (LiveWorld provided relevant comments to the FDA in March of 2010.)
Whether pharma companies do such moderation themselves or outsource to a company like LiveWorld, it’s important to have a program in place, with focused process and attention on off-label use and adverse events. Essentially, that means a connection into the brand’s normal process for reporting adverse events when all parameters for submission are present (identifiable patient, identifiable reporter, specific product involved, and adverse event). Since Facebook doesn’t provide brands with user e-mail addresses, and since brand Pages can’t send private messages to users, this often means responding to a comment that suggests such an event with an address to which the user can write, providing the appropriate information for potential reporting (according to the company’s normal reporting processes). The brand’s Page should also include a clearly-stated process or form for reporting such events.
We also recommend that fully identified, credentialed brand representatives regularly participate on the Facebook Pages, help answer questions, and interact knowledgeably with people — whether discussing valid issues, providing guidance, or correcting misinformation. That way, the company takes and demonstrates full responsibility for the content it provides in its advertising, product-related content, and any articles, blogs, and comments its own people make. And the public gets accurate information, a channel for interaction around questions or concerns, and the opportunity to benefit from the collective experience and input of other brand customers.