FORCING

PHARMA’S
HAND
FACEBOOK’S POLICY CHANGE AND THE FUTURE OF
REGULATED HEALTHCARE MARKETING

Spring 2011 Peter J. Pitts Brad B. McCormick

Global Head Executive Vice President
Regulatory and Health Policy Global Digital Director
Porter Novelli Porter Novelli

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 PETER J.PITTS BRAD B. McCORMICK
GLOBAL HEAD, REGULATORY EXECUTIVE VICE PRESIDENT,
AND HEALTH POLICY GLOBAL DIGITAL DIRECTOR

OVERVIEW
After much speculation, Facebook confirmed its plans to remove the disable comments option on most
Facebook fan pages. This policy will be immediately applicable to all new Facebook pages and will be applied
retroactively to all existing pages by August 15. Pending a review, only Facebook pages that are focused on a
specific prescription medication may continue with the comments option disabled.

Ostensibly this means that companies that have been using Facebook as a one-way broadcast tool are going
to be presented with a clear choice: Either find a way to embrace and benefit from two-way dialogue with
your Facebook fans, or remove Facebook from your marketing mix entirely. This will force regulated health
companies to examine not only the risk and benefits of Facebook, but of two-way social communication
overall. There is no correct choice here.

While a Facebook page is not right for every pharmaceutical campaign, we do believe that for most, the
benefits far outweigh the risks and could help usher in a new era of pharmaceutical marketing.

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WHY THE CHANGE?
Before elaborating on what this policy change
means, it is worth discussing some of the possible
motivations behind it. Facebook’s official statement
said that it is seeking “consistency” for its pages‘
product and wants to “encourage an authentic
dialogue between people and businesses on
Facebook.” While the reasoning behind these
principles makes sense, there are two deeper
trends that may shed additional light on
Facebook’s potential motives.
First, the policy may actually be an attempt to
make Facebook more attractive to regulated
healthcare marketers, not less. By forcing two-way
dialogue, Facebook may actually be improving the
performance of non-branded health content within
the social network. One of the top misconceptions
about Facebook is that a brand’s updates are
automatically placed into a fan’s Facebook newsfeed.
In actuality, each Facebook page contains two
separate newsfeeds: “Top News” and “Recent
News”. “Top News” is the default view of every
user’s Facebook page and contains all the news and
updates that Facebook’s proprietary “Edgerank”
algorithm determines individuals may be interested
in. “Recent News” contains all additional news and
is quickly becoming a less favorable feed for many
Facebook users.
While Facebook has never disclosed the full logic
behind its algorithm, we do know the number of
comments a particular update receives is a main
determinant as to whether an update makes a
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user’s “Top News” feed. For example, a news
update with five comments has a much higher
likelihood of making it past “Edgerank” as opposed
to an update with no comments. Therefore, by
disabling commenting, pharmaceuticals companies
are actually preventing their own updates from
appearing in their fans’ “Top News” feed.
Additionally, Facebook’s Sponsored Stories, a new
advertising platform that incorporates fans’ activities
into paid ads, is partially powered by fans’ ability
to comment on and “like” a brand’s news update.
Facebook’s policy change could in turn make these
new ad units more attractive to regulated healthcare
marketers.
Second, the increase in commenting and
engagement with Pharma content provides
Facebook with valuable information it currently lacks:
Trend data on how consumers interact with health-
related social content. As most are aware, Facebook
makes the majority of its money via advertisements.
Its vast amount of user data has turned the social
network into the most targeted advertising platform
in existence. However, unlike less regulated industries
(e.g., automotive, fashion, food, etc.), Facebook does
not have the same amount of user data for FDA-
regulated companies. As Facebook continues to look
to Pharma for potential customers, stronger health
data will allow Facebook to increase volume, and
perhaps advertising rates of Pharma media buying.
Turning on comments may be a way to obtain
more of this data.
 “BY FORCING TWO-WAY DIALOGUE, FACEBOOK
MAY ACTUALLY BE IMPROVING THE PERFORMANCE
OF NON-BRANDED HEALTH CONTENT WITHIN THE
SOCIAL NETWORK.”

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Photo provided by Creative Commons / cambodia4kidsorg

WHAT DOES THIS MEAN?
Starting now, any new Facebook page will be unable
to prevent its fans from commenting upon the
content they share on their Facebook pages. Only
branded pages dedicated to a specific regulated
healthcare product (with the name of the product
in the page title) may continue to have comments
turned off, pending review. Existing pages that
currently have commenting deactivated will no
longer have this privilege after August 15th. Again,
the choice here is to embrace users and allow them
the ability to supply comments or feedback, or to
dismiss Facebook entirely.
In many ways, this development is revealing a truth
many healthcare marketers instinctively know but are
often forced to ignore: It’s not “social media” when
a company disables the very ability of users to be
“social.” Disabling comments on a Facebook page
is like only showing black and white programming
on an HDTV. The full capabilities of a platform are
not realized when the primary functionality of that
platform is disabled.
But as Benjamin Franklin once said: “Every problem
is an opportunity in disguise.” While certain
Facebook strategies and approaches may have to
be reexamined, we believe this change provides
pharmaceutical marketers with an excellent
opportunity to finally acknowledge and embrace the
full capabilities of two-way social communication.
We see three primary benefits to regulated
healthcare embracing two-way dialogue:
1. The Rise of Pharma Corporate Communications:
For the past 20 years, the majority of
pharmaceutical marketing budgets was
dedicated to promoting specific products.
Now, due to both a less robust drug
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development pipeline and an increase in
the rates of patent expirations, the next
era of marketing may be that of corporate
communications, at least in part. And
Facebook’s policy change may help reinforce
that. The fact the Facebook will continue to
allow comments to be turned off for product-
specific pages means that most of those
pages will most likely continue as one-way
mechanisms, if they continue at all. Meanwhile,
non-branded corporate communication pages
will have the opportunity to evolve as full-
fledge engagement platforms. As they do, they
will command bigger teams, bigger budgets,
and yes, more prestige than they did in the past.
2. Foster Corporate Brand Loyalty in an Era of
Generics: If anything, the blockbuster era of
the pharmaceutical industry will be replaced
by the Era of Post-Patent Medicine. Besides
patent expirations and a slowing pipeline, the
increasing attractiveness of emerging markets
will usher in a new era of generics. There is
much greater price sensitivity to medication
in emerging markets, which means the
blockbuster pricing of the past won’t work. To
compete in this new era, Pharma companies
will need not only a robust portfolio of generic
medication, but an army of brand loyalists
as well. Global corporate communications
programs, supported by social media in general
and Facebook in particular, could be one
tool. Facebook is the single most expansive
communications platform in the world and
has been used by other global industries to
foster brand loyalty. As consumer packaged
goods companies have always known—when
the ingredient in two competing products is

“DISABLING COMMENTS ON A FACEBOOK PAGE
IS LIKE ONLY SHOWING BLACK AND WHITE
PROGRAMMING ON AN HDTV.”
essentially the same, the strength of a brand’s
equity can make all the difference. But now a
brand will be less about the product itself, and
more about the company that manufactures it.
Customers who value exchanges with a certain
company in social media will potentially continue
to purchase a company’s product instead of
choosing one with no established relationship.
Photo provided by Creative Commons / Grumpy-Puddin
3. Help Increase Patient Education and Increase
Prescription Compliance: It is estimated that
Pharma loses $30 billion a year in patient
non-compliance. This statistic is particularly
alarming when one considers the time and
capital Pharma spends to improve patient-
provider interaction. True two-way social media
has the potential to serve as a health education
platform by helping to keep patients informed
of the dangers of non-compliance, while
also earning their trust through transparent
dialogue.
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WHAT TO DO?
Inherently, this policy change is going to force many
regulated healthcare marketing teams to revaluate
Facebook. That is a good thing. There are too many
one-way Facebook pages that generate little value to
either the brand or the audience. It had been far too
easy for companies to set up a Facebook page, turn
off comments, and then pat themselves on the back
for “being on Facebook.” Once the policy changes,
those days will be gone. In order to really be able
to say “we are on Facebook,” Pharma companies
must make a manpower commitment that was not
required in purely one-way communication.
Indeed, we see a possible increase in manpower as
the only true obstacle toward Pharma embracing
two-way communication. As we have stated
before, there is no FDA regulation that prevents
pharmaceuticals companies from engaging in two-
way communications with customers. Not one. There
are certainly guidelines that need to be respected.
But just as DTC AD must give fair balance to adverse
events or face warning letters, so too can two-way
communications work for Pharma as long as the
guidelines are followed. Following the guidelines
is where the manpower requirement comes in. For
marketing teams who have deemed Facebook worth
the investment, we see several roles that are critical:
• Ensure that all Facebook planning is integrated
and complements larger marketing efforts, both
online and off. This is easier said than done,
and often proves one of the more challenging
requirements for many marketing teams.
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• Hire a community manager to facilitate any and
all communications on the fan page. Depending
on the size and activity of the Facebook
community, this could be a part-time or fulltime
person and could be someone from an existing
customer support time.
• Devise an escalation plan and workflow for
all possible incidents including adverse event
reporting, of off-label use, corporate criticism or
blatant product misinformation.
• Install a third-party tool like Buddy Media or
Virtue that will allow increased administration
and include keyword related email notifications.
• Bring in a metrics analyst on a regular basis
to examinee content performance and
recommend ways to optimize it for both for
Edgerank and increased user engagement. It is
also essential that key performance indicators
are set up against the larger marketing
objectives and constantly gauged.
Overall, we see Facebook’s policy change as a welcome
development in pharmaceutical marketing. We
believe this will help evolve the profession overall, and
help usher in a new industry era based on increased
transparency, dialogue and new market growth.
 Photo provided by Creative Commons / ausnahmezustand

“PHARMA COMPANIES MUST MAKE A MANPOWER

COMMITMENT THAT WAS NOT REQUIRED IN PURELY
ONE-WAY COMMUNICATION.”

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Photo provided by Creative Commons / catspyjamasnz

 Photo provided by Creative Commons / baileyraeweaver

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