Pharma Facebook Commenting Is Open: Remain Calm

Whether anyone is listening to me or not, I’m not sure. For the most part, I feel like Kevin Bacon in this classic clip from Animal House.

Today is the day that many pharma and healthcare companies that like their Facebook Pages hoped would never come. Remain calm.

Today is the day that they no longer can prevent people from commenting on their Wall posts thanks to some changes implemented by Facebook. You can read all about the issue in this post.

The short story is this. In the past, pharma and healthcare companies were able to ask Facebook for a special exception that allowed them to prevent people from being able to Like or comment on their Wall posts. This was a convenient way to avoid having to answer the question about how to deal with user comments about products that might be off-label or contain an adverse event. Today, they need to answer that question. Each company with a Facebook Page needs to decide how to handle this. Some will simply allow the change to happen and let people start to comment. Others will take their Pages down rather than allow commenting.

For those who follow this page or regularly check in on the Pharma and Healthcare Social Media Wiki, you know that there are no shortage of pharma Facebook Pages out there. However, there are fewer today. Over the weekend, I cleaned up the Wiki and removed any Page that didn’t exist (you’ll see them labeled with “UPDATED”). These are pages that were removed for any reason. Some are campaign-based Pages that were taken down after the campaign ended and others left for reasons I can’t tell you. After the cleanup, I created a new page on the blog called: Pharma and Healthcare Facebook Page Deathwatch. On this page, I listed every remaining Facebook Page (and the ones already removed) and divided them into three main groups:

  • Pages removed on or after August 15: these would be the Pages that were removed rather than allowing comments and Like
  • Pages on “Deathwatch”: these are pages prior to August 15 did not allow comments, so have to decide whether to allow them or take the Page down
  • Pages that already allow commenting: yes, already allow them and have for a while and the world hasn’t ended

Every Page fell into one of these categories. I started the Pages removed category with four entries when I created the page on Friday, August 12. Today, I checked all the Facebook Pages on the “Deathwatch” list and I’m disappointed to say that I’ve added six more Pages to this category. A total of 10 Pages have now been removed rather than allow commenting. Every other Page now currently allows comments or Likes.

Or do they?

As of 8:30 AM EDT on August 15, none of the Pages that had comments and Likes blocked actually have a way to comment on them. That is, it doesn’t appear as if Facebook has actually turned on comments on any of these Pages. So, for now, you actually can’t comment on them. We’ll see if this changes later in the day or if there is some delay in this change. Did Facebook get cold feet? Did pharma manage to convince Facebook to change its mind? Did someone at Facebook forget to flick a switch? Stay tuned, as we are trying to contact Facebook for more information. This is an odd development, as several Pages have actually posted today announcing that you can comment on their posts, yet there is still no way to do it. So, I’d imagine that it comes as a surprise to these Pages as well (as it frankly doesn’t make them look too good through no fault of their own).

As to the entire issue about commenting, I do have a few things to say.

First, if you don’t allow commenting, then don’t bother having a Page. Here’s why: if you don’t allow commenting (and, in fact, encourage people to comment), then you’re Page doesn’t exist. You can read my full explanation why in this post. A recent study from ComScoreshould help you to see why. This one chart should sums it up.

People don’t go directly to your Page. They spend time doing a lot of other things on Facebook. Most critical to Pages is that people spend 27% of their time on Facebook looking at their News Feed. The content in the Newsfeed is ranked by something called EdgeRank (an algorithm used by Facebook). Two of the three criteria for ranking depend Likes and comments. That is, unless you allow Likes and comments, your content NEVER shows up in ANYONE’S News Feed. If it’s not in the News Feed, then people don’t see it. If you have a Page that doesn’t allow comments, log in as admin and look at the number of impressions that shows up underneath each post. Ever wonder why that is so much lower than the number of Likes you have? Well, it’s because your posts aren’t being shown to anyone. So, Facebook forcing Pages to allow Likes and comments should be a blessing. Companies spend a lot of time and resources on these Pages and they’re a complete waste unless someone knows they’re out there. So, with comments on, maybe it won’t be a waste of time and money to maintain a Facebook Page.

I was asked some questions and quoted for a Washington Post article about these changes to Facebook Pages and you’ll get more of a sense of my views on this topic in the article. I like being the contrarian every once and a while.

One excuse I’ve heard from companies that are worried about commenting being open is that they’ll have to monitor Pages 24 hours a day, seven days a week in case someone posts something “bad”. They seem to be particularly afraid of adverse events. First, no one is sitting by waiting for your Page to allow comments so they can post an adverse event. People just don’t do this. There’s plenty of data out there showing that there are very few reportable adverse events out there posted on social media sites (including Facebook). Remember, when someone posts on your Page on Facebook, it goes into their profile and to their friends’ News Feed. Do you think they want to share the adverse event they had while on your drug with everyone on Facebook?

Assume for a second that they do and they post something. Why is 24/7 monitoring so important? The reason I keep hearing is so that companies can remove adverse events and off label comments as quickly as possible. The theory these companies have is that if they remove them quickly (almost instantly), then somehow they have no liability for what was posted (i.e., accountability to the FDA). This is not really sound logic. First, you have to assume that the FDA holds you responsible for comments made by others on your Facebook Page. The FDA has never indicated that this is actually the case. Once more…the FDA has never indicated that this is actually the case. Having said that, they also haven’t said that you’re not responsible for them. Facebook is a grey area. Yes, pharma companies control the Page, so they have accountability for what’s posted. However, they don’t fully control it, as people can leave comments and there’s nothing (now) that pharma companies can do to prevent it. Is the FDA really going to hold you responsible for these comments assuming you handle them once they’re posted in good faith? If they do hold you responsible, then they shouldn’t allow pharma to have Facebook Pages because there’s no way to prevent people from leaving comments, so there’s no way for companies to stay compliant. If they can’t ever stay compliant, then they shouldn’t allow companies to have Pages.

I don’t think the FDA has this intent. If they did, they would have already cited any one of the twenty or so industry Pages that have allowed open comments for a while (see this Page for the list). Back to the logic that comments must be removed instantly or there’s more risk making Page management impossible, I don’t buy it. Let’s be clear, if you post something off label on your website, for example, for 10 minutes are you not in any trouble because it was only up there for 10 minutes? How about if you posted it for 1 minute? 10 seconds? Nope. In each case, you’re in the same amount of trouble. That is, unless your logic is that the FDA won’t notice if it isn’t up for very long. You’re not trying to hide stuff from the FDA are you? The fact is, you’re liable whether it’s up there for a minute, an hour, or a week (or more). Same thing applies for Facebook comments in my opinion. If someone posts a comment that contains off label information on your Facebook Page and you think that you’ll be in trouble according to the FDA from this, then it doesn’t matter whether you delete it in 10 minutes or 10 hours. You’re in the same amount of trouble most likely. Of course, I don’t think you’re in trouble at all, as I’ve already said. Point is that this isn’t a valid argument for why allowing comments isn’t possible. Let people post comments, get your sleep, and address them when you wake up by deleting them or leaving them. You’re in the same trouble either way (which, again I don’t think is any trouble).

Just remember this, whether you choose to listen to me or someone else. There are at least 10 pharma industry Facebook Pages that have allowed (and even encouraged) people to comment for quite some time. None of these companies have ever received a Warning Letter or Notice of Violation from the FDA.

19 Responses to “Pharma Facebook Commenting Is Open: Remain Calm”

  1. Mark Davis August 15, 2011 at 2:04 pm #

    Breaking news. Facebook today added new ISI space on Healthcare page walls, same day commenting enabled.  http://on.fb.me/FB_ISI_Test

    • Jonathan Richman August 15, 2011 at 2:18 pm #

      That’s handy. Let’s see when they actually turn the commenting on today. Nothing yet.

      • Marina August 16, 2011 at 3:52 pm #

        Just commented on it.

  2. Mark Davis August 15, 2011 at 2:04 pm #

    Breaking news. #Facebook today added new ISI space on Healthcare page walls, same day commenting enabled.  http://on.fb.me/FB_ISI_Test

  3. Bruce Grant August 15, 2011 at 5:22 pm #

    Damn, Jon…you’re a national treasure.

    • Jonathan Richman August 15, 2011 at 7:00 pm #

      Hah! Thanks. Hadn’t gotten that one before. I should add it to my business cards.

      • Semantelli August 17, 2011 at 12:36 pm #

        You should Jon. You really are a great asset to the pharma social media community.

        Siva Nadarajah
        CEO, Semantelli Corp.
        Semantelli releases
        AETracker to help pharma stay on Facebook.http://t.co/aHsZuqn 

  4. JennaWoodul August 15, 2011 at 6:04 pm #

    Thanks, Jonathan. Agreed that the threats are over-stated. At LiveWorld, we’ve
    just released a new study on incidence of Adverse Events covering multiple pharma Facebook Pages’ user content in the last few months. Turns out, no matter how many fans or posts, the AEs come in at about 2%. Moderators escalate them to the
    companies for insertion into their regular reporting processes (assuming they
    are even reportable, according to FDA criteria: identifiable patient, identifiable reporter, specific product involved, and adverse event). The brand’s Page should also include a
    clearly-stated process or form for reporting such events.

    Pharma companies who shut down their Pages are missing the big opportunities:  Customers could get accurate information from experts.
    People could talk with each other about their experiences living with
    health issues. And pharma companies could hear directly from customers who use
    their products. When people put issues and questions on a pharma Page, the
    company has the opportunity to respond, correct, or connect with the
    commenters, while simultaneously educating other who follow the Page. People
    will be talking anywhere and everywhere, and it’s much harder to respond to
    comments (positive, critical, or off-bases) posted on any of the thousands of
    possible venues across the social web. Ideally, we’d suggest that fully
    identified, credentialed brand representatives regularly participate on pharma
    Facebook Pages, help answer questions, and interact knowledgeably with people.
    As part of a strategic programming plan, expert content can also support the
    continuing visibility of a pharma Page in customer NewsFeeds, given EdgeRank
    (which constrains non-interactive Pages to invisible digital brochures, as you
    note). The company thus takes full responsibility for its product-related
    content, and the public gets accurate information while benefiting from the
    collective experience and input of other customers.

    • Jonathan Richman August 15, 2011 at 7:06 pm #

      Thanks for sharing the data. A question on the 2%…is this 2% of all posts and comments from users? If so, what is the total number? That is, 2% of what? I ask because 2% seems low, but if it’s 2% of 1,000,000 it’s still a lot of work. I’m going to guess it’s nothing like this, but many might look at 2% and still see a lot of work. I’ll guess that 2% amounts to less than 10-20 posts tops across all the Page, but would still like to know the absolute numbers just for further reinforcement of the message.

      • JennaWoodul August 15, 2011 at 8:38 pm #

        This was 9,000 posts from users over a 3-month period.

      • JennaWoodul August 15, 2011 at 8:38 pm #

        This was 9,000 posts from users over a 3-month period.

      • Stacey Mahoney August 17, 2011 at 5:50 pm #

        I agree, John. It’s a lot of work. Even if that number is a happily low 2%, the time and effort that must be expended to keep an eye out for that 2% is significant.
        And what happens if they fall outside of that industry benchmark? There
        is so much fear for pharma within the social space right now. This new change with Facebook creates another barrier that the industry was not looking foward to.

         

        • Jonathan Richman August 19, 2011 at 12:15 pm #

          Hold on…I said it would be a lot of work if it were a million comments. It was 2% of 9,000 spread over 3 months (180 comments total, 60 per month, 2 per day) across multiple company Pages. So, in the worst case, if this were one company, they’d have to worry about 2 posts per day. However, this is spread across multiple companies, so the burden is even lower (maybe less than 1 on average per day).

          I’m surprised that it is as high as 2%, so I’m not sure what the definition of an “adverse event” was here, but this is much higher than the % of reportable adverse events usually seen (around 1 in 500). Perhaps the LiveWorld definition was broader so as to describe it as a worst case scenario.

  5. Semantelli August 17, 2011 at 12:46 pm #

    Thanks for the update Jon. Ever since we released Facebook AETracker our phone started ringing,  which is a sign that companies want to continue on Facebook. AEtracker automatically detects potential AEs, off-label comments and product misinformation and routes them to moderators to take action. We also provide 24 x 7 human support to help companies report AEs in a timely manner.

    Siva Nadarajah
    CEO, Semantelli Corp.

    Semantelli releases AETracker to help pharma stay on Facebook.http://t.co/aHsZuqn

    • Jonathan Richman August 17, 2011 at 2:03 pm #

      Is there a demo of this AETracker somewhere? I see you post about it all over the place, but no one I know has ever seen it in action before. Does this use the native Facebook Wall or does it use some sort of “custom wall”? I’m going to assume that it’s the latter in which case I’m likely not going to be a fan of it. These “custom walls” simply don’t distribute content onto people’s News Feeds like the native Facebook Wall does. If an application like a custom wall can’t do this effectively, then there’s no point in having it or the Page because no one even knows that it exists. People find updated Facebook content through their News Feed. If your content isn’t there, then your Page pretty much doesn’t exist.

      Every “custom wall” I’ve encountered isn’t effective in getting content in News Feeds. That should come as no surprise based on how Facebook determines which content appears in the News Feed.

      • Semantelli August 17, 2011 at 3:28 pm #

        Hi Jon,

        Thanks for the note. Ours is not a custom wall ( we are not fans of this either, which we think defeats the whole purpose of Facebook). We help customers with native facebook pages. We monitor these native pages in real-time and automatically find AEs, off-label and product misinformation via Semantic mining (a level higher than text mining). Our workflow engine then routes them to appropriate people via email and text messages to take action. We also have 24 x 7 support to help our clients report them to FDA. This is what FDA wants – treat Social Media like another channel. 

        We think, moderating feedback from patients and doctors via custom walls will eventually make them go somewhere else (worst create alternate –  negative –  facebook pages) hurting the brand image.

        Facebook is all about social conversations which shouldn’t be unidirectional. You just accept feedback and report any AEs (2% based on research) to FDA. This will make everyone happy :-)  Consumers are happy their feedback is heard. Doctors are happy their feedback is heard. FDA is happy you are a good corporate citizen. 

        Eventually you are bringing better health outcome.

        We’d be happy to demo our product whenever you have some time.

        Thanks Jon.
        Siva

  6. Michael Hoskins August 18, 2011 at 6:16 am #

    From the patient-perspective, it seems that Pharma is too often disconnected to the reality of social media. It’s supposed to be a two-way conversation, not one filtered by companies who are too worried about possible FDA regulatory issues. If they are open and transparent, as they should be by the whole spirit of regulation, then Pharma doesn’t have anything to worry about. Filtering comments is just a turn off to the people who turn to the online world for answers, and it’s not as if people are going to see comments posted on a Pharma company’s wall and suddenly think that is what the company is saying about the product or issue. People will go where they need to for full discussion, and if Pharma isn’t willing to be a part of that discussion, then really they shouldn’t be on Facebook or in the social media world to begin with.

    • Jonathan Richman August 19, 2011 at 12:10 pm #

      A fair point for sure, the the issue isn’t whether people will consider a post from a user to be what the company actually thinks. It’s whether or not the FDA believes it’s the same as if the company posted. Unfortunately, logic and intent isn’t the way they look at it. So, going by the “spirit” of the regulations is a sure-fire way to get in trouble.

      Having said that, the FDA has never indicated in any way that pharma companies would be held liable for what people post on their Facebook Walls. That’s an assumption made by many companies and I’m not sure it’s an accurate one. I think the FDA understands that pharma companies can’t control if someone posts something that might violate a rule. They are more likely worried how companies handle this when it happens. If the FDA thought that pharma companies were responsible (same as if they posted it themselves) for user comments on a company’s Facebook Wall (for example), then they should probably simply tell pharma companies to stay off Facebook. Since companies can’t control what people do and they’re responsible, it would be completely illogical to be Facebook. However, I don’t really think this is the reality, but companies prefer to lean towards being conservative in this area.

  7. jas_cinammonagency August 22, 2011 at 9:22 pm #

    If more proof were neede that Facebook is taking over the world….