New Facebook Rules: A Challenge and an

Opportunity for Pharma

Summary:  A new Facebook policy will require all pharmaceutical companies to leave wall comments enabled on their Facebook pages. The rule not only leaves pharma companies open to public criticism, it also complicates federal rules requiring companies to report all stated drug side effects to the relevant authorities, a rule set in 1993, long before the advent of social media. However, Facebook is an opportunity for pharma - not an obstacle. The key is to embrace, rather than fight, its open features.

Like many pharmaceutical companies, Johnson & Johnson has tip-toed into Facebook with a careful step. With over 15,000 likes and a constant stream of consumer-friendly company news bulletins and heart-warming links, J&J’s Facebook page almost seems a success. But despite their best efforts, the page is under constant flak from consumers, with numerous negative comments littering otherwise thoughtful posts.The comments stem from several issues. In particular, campaigners have posted frequent criticism towards J&J for not joining a patent pool to lower the cost of HIV treatment. Whilst this poses a threat to J&J’s reputation, still other issues are far more concerning from a regulatory standpoint. In particular, numerous drug users have posted claims that certain J&J drugs - particularly Levaquin - cause dangerous side effects. This leaves J&J in a bind - with a Facebook wall open to consumer claims of adverse drug effects, how do they handle these claims with the necessary regulators?

The Problem with Adverse Events and Adverse Effects: No Clear GuidanceIn order to understand J&J’s - and all of pharma’s - dilemma, we need to understand two things: adverse events and adverse effects.An adverse event is any adverse change in health or side effect that occurs in a person who participates in a clinical trial while the patient is receiving treatment or within a previously specified period of time after the treatment has been completed.

An adverse effect is a harmful and undesired effect resulting from a medication or other intervention. In many countries - including the United States and the United Kingdom - pharmaceutical companies are required to report adverse events and adverse effects to the drug regulatory of the respective country.  However, when these events are reported in an open forum such as Facebook, it’s not exactly clear how the pharma company should respond.For example, as of now, there is no FDA guidance that explains how current regulation applies to online discussion (this despite pharma marketers’ request for clearer guidance in 20091). The current guidelines give four parameters for submitting information about adverse events. The pharma company should have knowledge of

1 An identifiable patient2 An identifiable reporter3 A specific drug or biologic involved in the event and4 And adverse event or fatal outcome

However, it is unlikely that an adverse claim posted on a Facebook wall will contain all four pieces of information necessary to make a report. In fact, in a Nielsen study of 500 healthcare-related messages posted online across multiple disease categories, they found that only 56 (11%) of messages contained enough information to submit a report2.  

However, these guidelines were set in 1993, long before the advent of social media, and pharma’s demand for an update is understandable. Without clear rules, Facebook remains a hazy marketing area for companies like J&J. Their Facebook page illustrates why many pharma companies are wary of Facebook, with many having little or no presence whatsoever (Abbott Laboratories, Merck & Co. and Eli Lilly just to name a few).

1 Still No Answers For Digital Pharma Marketers, Says FDA, Kate Kaye, Clickz.com, 23 Dec 20102 Listening to Consumers in a Highly Regulated Environment, Melissa Davies, Nielsen Online, August 2008

Pharmaceutical Companies on Facebook3

Company Facebook Presence

Comments allowed

Fan Count

Abbott Community Page No 6,458

Amgen Community Page No 1,215

AstraZeneca Official Page No 10,198

Bayer Official Page Yes 533

Boehringer Official Page Yes 12,134

Bristol-Myers Community Page No 270

Daiichi Sankyo Community Page No 270

Eli Lilly Community Page No 3,092

GlaxoSmithKline Official Page No 10,012

Johnson & Johnson Official Page No 15,589

Merck & Co. Official Page No 946

Merck & Co. Community Page No 2,489

Novartis Official Page No 6,521

Novo Nordisk Official Page Yes 3,568

Pfizer Official Page No 26,482

Roche Careers Page Yes 3,128

Sanofi-Aventis Page for Initiative Yes 706

Sanofi-Aventis Community Page No 6,107

Takeda Community Page No 425

Teva Official Page No 1,015

3 Fan numbers were gathered on 8 June, 2011. Community Pages are pages created automatically by Facebook; they include a wiki article description, cannot be edited by users and do not contain a Wall for fans to post on.

Until recently, pharma companies took some comfort in the ability to disable comments on their Facebook pages, thus sidestepping all regulatory issues around adverse events and effects. This month, all that changed.

Facebook Tells Pharma They Must Allow CommentsPharmaceutical companies currently have the option to enable or disable commenting on their Facebook page.  However, in line with its effort to ensure Facebook remains an open platform, Facebook recently changed its policy that allowed high-risk pharmaceutical businesses to turn off commenting4. Now, Facebook pages with comments disabled have until August 15 before open comments become a requirement.

The rule change has many pharma brands in a panic - one look at J&J's Facebook page shows you why. No doubt, the comment policy will be a challenge, but it also presents an opportunity for pharma, who have so far seen limited success in using Facebook for marketing and PR.The new Facebook rules are poised to change the way pharma manages comments on Facebook. At present, various tactics are used to moderate unwanted posts.J&J's page appears lightly moderated, with the result of constant negative commentary from consumers. Sanofi-Aventis’ VOICES page, however, appears heavily moderated - despite posts claiming an excess of 100 comments, only a small handful of comments (less than 10 in one case) are visible. This suggests that the other comments have been deleted, which makes you wonder just how bad those 90+ comments were. Boehringer Ingelheim is the only pharma company we found which successfully uses Facebook as a positive engagement tool. For example, their Facebook page shows positive activity fuelled by a photo contest as can be seen by the top terms used in conversation.

4 Facebook Tells Pharma Brands They Must Allow Comments, Kate Kaye, Clickz.com, 20 May 2011

Source: Skyttle Friends Facebook Analytics

Negative comments are hard to find and are most likely removed in accordance with their usage policy, stated clearly on their Welcome page:The company reserves the right to delete any postings at its sole discretion (sorry - we know it's not very social media but we work with serious medical conditions and we can’t risk unmonitored or unverified medical advice being published).

This Facebook challenge is very real for pharmaceutical companies. After all, how do you leverage an open platform when you own brands that commonly fall under consumer scrutiny? Some pharma companies have handled this by staying away from Facebook altogether. But others, like J&J, Sanofi-Aventis and Boehringer Ingelheim, are testing the Facebook waters and slowly catching on. Facebook's new rules may seem like a shark in the water, but in fact, they're an opportunity. Openness doesn't pose a threat to brand reputation; it offers an opportunity to manage reputation in a productive and positive way.

Case in point: BP Gulf Oil SpillLike pharmaceutical companies, oil companies too must constantly play defence to consumer criticism. Take a PR disaster like the BP oil spill in the Gulf of Mexico, a disaster which made BP's Facebook page a prime channel for consumers to vent their outrage.

BP could have deleted the comments, or deleted their account altogether, but instead, BP saw an opportunity to use Facebook's popularity to manage the conversation.BP recognised that consumers needed a place to express their concerns, stay informed and - most importantly to BP - stay aware of what BP was doing to rectify the situation. So BP set up two separate sections of their Facebook page: “Gulf Updates” and “Voices from the Gulf”. The effect was to channel conversation about the oil spill away from their main wall and onto these topical pages. They also published a friendly but firm “commenting” policy that encourages "constructive, respectful" but disallows vulgar, obscene or threatening comments.

As bad as the oil spill was for BP, Facebook allowed BP to protect its reputation and manage the conversation by doing two things:

• Providing something useful to consumers - information -

that both educated consumers and advertised their positive efforts to repair the damage.• Portraying an honest, sincere voice that demonstrated BP's

desire to engage in constructive dialogue about the brand, be it about the oil spill or other company activities.

The result is a boon to BP's overall Facebook presence, which continues to attract fans and positive comments on its various content pieces.

BP illustrates how any company - including pharmaceutical brands - can use Facebook to manage conversations, even those that seem potentially harmful. The key is in understanding what Facebook is good for and why it's such a powerful platform for consumer conversation and brand interaction. In other words, you have to embrace - not fight - Facebook's open features.

Pharma on Facebook: How to Make it WorkOur own studies for pharmaceutical clients have shown that Facebook is an important influencer in the exchange of health information. Therefore, there is much to gain from joining the conversation, provided you approach Facebook systematically.Four things are key to pharma’s use of Facebook to ensure it gets the most benefit while still abiding to regulations around adverse event reporting:

• Structured management

• A clear policy on commenting for your Facebook page

• Listening (including monitoring)

• Sincere engagement

Structured management means putting someone in charge of Facebook who takes an active role in conversations and is responsible for ongoing monitoring and moderation of Facebook comments.A clear commenting policy posted publicly on your Facebook page will allow you to moderate conversations in line with what you intend your page to be used for. This means you can delete inappropriate comments as you see fit. Boehringer Ingleheim has done an excellent job of this on its Facebook Welcome page by posting a clear policy that allows them to remove potentially damaging comments.A listening strategy should include some form of rigorous monitoring to ensure you catch all comments that require action. In particular, any comments that are inappropriate should be removed, and any reports of Adverse Effects should be investigated and reported if necessary. But listening isn’t all about dealing with problems; it’s also about getting consumer insights from people having real conversations about you and your products. The true value of a Facebook page comes from sincere engagement with users. Comments, even negative ones, reveal endless insights valuable to the brand:

• Popular topics of conversation reveal what consumers care about, good or bad

• Negative feedback allows you respond to problems directly and points to opportunities to improve products and services

• Positive comments provide great word of mouth and potential ideas for positive PR campaigns

• Popular discussions and wall posts reveal which ideas resonate with consumersBut in order to get at these insights, you need to have one thing: a sincere voice, especially in the face of criticism.This is where most pharmaceutical companies seem to struggle. A successful Facebook page needs an authentic voice that cares about its fans issues and responds with a sincere, honest touch. People like a Facebook page because they're looking for this voice, a voice that they respect and want to engage with. After all, would you want to have a conversation with someone as dull as a doornail who keeps bringing up the family picnic even though you keep telling them how devastated you are over your recent cancer diagnosis? No, give me some sympathy, and tell me something that might help!In Johnson & Johnson's case, they don't necessarily need to join the patent pool to win over their Facebook fans. But they do need to give something back that's useful and sincere. For example, several topics are currently driving negative commentary on J&J's Facebook page, particularly specific drugs like Levaquin, and the Medicines Patent Pool.

Taking a cue from BP, J&J could start posting news about their current activities around these issues, or even start a page that directly addresses these concerns. More importantly, J&J could respond to comments, especially those that are respectful and constructive, albeit negative about the brand. J&J's participation would be both a gesture of goodwill and an opportunity to learn about their customer's concerns. Moreover, it would help encourage positive conversation around their other, more positive, activities like the company sports team and their environmental work.Today's digitally connected world demands sincere engagement, particularly on a platform like Facebook. However, this demand makes Facebook a mechanism - not an obstacle - for sustaining positive PR and protecting reputations. Pharmaceutical companies are still in their early days of figuring this out, but those that do will be in a prime position to benefit from the 600 million people currently using Facebook.

About Market Sentinel

Market Sentinel is a thought leader in online conversation monitoring and analytics. We work with major brands from around the world to help them make sense of the web. Our tools and services include brand monitoring, benchmarking analysis and digital planning with Skyttle, a suite of on-demand social analytics tools. Our most recent addition to the Skyttle family is Skyttle Friends, offering in-depth Facebook analytics for any Facebook page, public or private.Market Sentinel's unique mix of business and marketing professionals, mathematicians, linguistic experts, software engineers and social media analysts creates best in class solutions that produces long lasting client relationships.

Source: Skyttle Friends Facebook Analytics