Several drug companies may have shuttered their Facebook pages prematurely in August after the social networking site revoked their exclusive privilege to block consumer comments on their walls.

Johnson & Johnson and AstraZeneca are among the drug companies that closed Facebook pages that catered to specific patient populations or ailments for which the firms offer treatment. They did so partly out of fear that if consumers posted comments that run afoul of FDA’s marketing restrictions for drugs, such as discussing off-label uses, the agency would hold them accountable.

Others fear that if they open their Facebook pages to comments, they will see a flood of adverse event reports.

The drug industry has options beyond disappearing from Facebook and missing the opportunities the influential networking site offers.

Pharma companies can remain safely on Facebook by redirecting conversations from their walls to a custom application tab where they can pre-monitor user comments and posts, pre- or post-moderating conversations on the Facebook wall or clearly defining and enforcing cultural rules for all users, said Peter Friedman, chairman and CEO of LiveWorld, a social media management and development company.

The threat of adverse event reports also is overblown, he said. A case study of five of the firm’s pharma clients that allowed Facebook comments revealed less than 2% of the more than 9,000 comments received in a three-month period were adverse events, he said.

But Friedman also understands why pharma firms are nervous about social media.

“Pharma companies generally are hesitant and inclined to be conservative” because their industry is highly regulated and they are accountable to FDA and the Federal Trade Commission for marketing.

Facebook’s About-face

Initially, Facebook accommodated the pharmaceutical industry’s unique regulatory circumstances and allowed drug firms to “whitelist” their pages, which meant they could request special permission to block comments on their walls, as well as photos and videos.

However, Facebook changed its policy and told firms that beginning Aug. 15 they would no longer be able to block comments.

The website explained in a letter to affected firms that the change would “encourage an authentic dialogue between people and businesses on Facebook.”

As a consolation, Facebook said firms could still whitelist their branded pages – for example, ones about specific products – but this provision appears to apply only to prescription drugs, and may be of no help to pages sponsored by or dedicated to OTC drugs.

Ways Around The Wall

One way to satisfy the social aspects of social media while complying with FDA’s and FTC’s marketing regulations is to establish and use an alternative conversation board instead of the traditional Facebook wall. Firms can do this by creating a forum tab in the left column on Facebook and redirecting users there from their wall through a single post.

Intouch Solutions’ PharmaWall is one example. It is an alternative to the traditional Facebook wall that allows people to comment, but before the comments are posted they funnel into a moderation queue where they are reviewed and accepted or rejected by an administrator, explained Jim Dayton, senior director of emerging media at Intouch Solutions.

Potential posters immediately receive a message that their comments are under review and will be posted if appropriate, he added.

Alternative tab moderation apps are a “good stepping stone to full open two-way engagement because [firms] can get an idea of what people will want to talk about on their post and get an idea of how they may want to respond,” Dayton said.

They also can protect against people posting inappropriate messages or misinformation about OTCs for which FDA could hold a firm accountable. FDA officials previously told marketers they are responsible for and should correct improper information from posters, such as claims that a dietary supplement can treat, cure or mitigate disease (Also see "FDA Officials Offer Pointers For Navigating Social Media Pitfalls" - Pink Sheet, 24 May, 2010.).

Custom applications in the tabs section of Facebook have a few shortfalls, though.

“Very few consumers interact on other tabs. The action is on the wall,” said Friedman, who also offers a custom application tab called Facebook Forums with pre-moderation.

If users cannot interact on the wall they might not make the transition to the tab – even with a wall post explaining where and how to comment on a tab.

To address this, LiveWorld is testing a pre-moderation system for the actual Facebook wall, which would eliminate the need for unpopular tabs and could increase user participation, Friedman said.

However, pre-moderation still is not a best practice, he said. He says consumers expect posts and comments to appear immediately, and the delay and pre-moderation might turn them off.

Post-Moderation Is Viable Compromise

Post-moderation is another alternative that sidesteps the drawbacks of pre-moderation.

LiveWire and Intouch Solutions, along with other firms, offer structural proactive moderation where moderators review comments in real time or at set intervals and either leave them on the wall, delete them or respond to them, depending on predetermined criteria.

The moderator should know how to address negative feedback about the product, comments about competitors or inappropriate use of the product and potential adverse event reports, Dayton said.

Constant moderation can boost the effectiveness of a Facebook page if the team also interacts with users.

For example, Merck’s Schering-Plough Healthcare Products business consistently interacts with users on its Facebook page for Claritin. The moderator frequently posts questions related to the allergy product that can stimulate interaction, such as “Who is going to enjoy the outdoors this weekend?” The moderator often responds quickly to those who answer.

LiveWire trains moderators “on the brand’s voice” and guidelines so they know how and when to respond to or flag comments for the firm to review. Software also can summarize the comments for easy analytical review by the firm.

Friedman explained the more interaction between a brand and fans, the more likely Facebook will distribute the brand’s news to its fans via the news feed feature.

Around-the-clock monitoring can be expensive and excessive, so Friedman recommends eight hours of monitoring daily. He said moderators should check the page every two or three hours during the day and once or twice at night to deal with the “dozens to hundreds,” but not thousands of comments received daily.

Firms that monitor pages closely should establish clear ground rules so as not to frustrate users who might wonder why their comments were deleted, Dayton said.

Procter & Gamble outlines the types of comments that will be deleted on the Facebook page for Prilosec OTC. It explains that it will remove any post about heartburn or using Prilosec OTC because “all comments must be consistent with the label, cannot suggest product use for conditions not indicated on the label and cannot reference competitive products.”

The page still thrives as a community center though because the company encourages users “to talk about your passion and the Official Sponsor of You program,” which is the drug’s online tagline. P&G also provides facts about frequent heartburn and using the drug, but tells users to see the full text on Prilosec OTC packaging.

Finally, firms looking to save on live post moderation should avoid auto-filters, Friedman warned. He explained a “best-case scenario is they miss 20% of the bad and 20% of the good and an adverse event might not be in a language that you can predict.”

For example, “someone might post and say, ‘Oh yes, I did that too and then I saw red balloons.’” Red balloons likely would not trigger an auto-filter, but a person would know that red balloons have nothing to do with drugs and would double-check the context of the post to see if the user was claiming to hallucinate from the drug or visiting the fair.

Another best practice for managing Facebook interactions is to “define a social culture” and enforce set rules, Friedman said.

Schering-Plough lays out on the Community Rules page that it does not necessarily endorse, nor is it responsible for, the accuracy of information, opinions, claims or advice shared by Claritin fans. It adds that users should call the consumer response center with any questions.

Disclaimers can protect firms to an extent, but FDA officials have clarified that once a firm knows of misinformation it must address it.

If firms still are uncomfortable, they can establish a clear policy of deleting comments after they are posted.

Waiting For FDA Guidance

The pharmaceutical industry’s reluctance to engage fully in social media is due partly to a lack of clear guidance from FDA.

The agency acknowledges that some advertising rules, such as providing disclaimers, do not work in all social media – especially sites like Twitter and Google, which limit words or characters.

FDA promises guidance that likely will not be “platform specific,” but so far it has pushed back or missed the delivery deadline twice (Also see "Social Media Marketing Guidance Available In Existing Regs, Experts Say" - Pink Sheet, 9 May, 2011.).

By Elizabeth Crawford

Firms Navigate Social Media Safely Following Loss Of Facebook Protection

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