What the new Facebook policy tells pharmaceuticals about branded vs. non-branded programs

There seems to be a lot of hand wringing around the recently announced Facebook policy that it will no longer allow pharmaceuticals to disable the comments feature on their pages. By being able to disable the comment function, the pharmaceutical could avoid having an adverse event or off-label usage reported on their Facebook page.

As AdAge reported, a digital-strategy chief at one of the top 10 pharmaceuticals had this to say about the new Facebook policy:

This kind of hurts us. In large part, having a Facebook page gets us in the social media door and not having comments keeps us in good graces with FDA.

Of course, some might wonder, at least as far as adverse events are concerned, whether disabling the comment function is like putting your head in the sand and hoping the danger will go away; and perhaps it would better to know and be able to deal with the issue? And, regarding posts on off-label usage, although Facebook doesn’t allow you to approve Wall posts before they are posted, you can always delete specific unwanted posts after they are posted; hence, a pharmaceutical go delete posts on off-label usage, but perhaps the “damage” would be done?

Arnie Friede, attorney at Arnold I. Friede & Asociates, provides a great perspective on this issue. Arnie specializes in FDA-related legal and regulatory matters. He was Associate Chief Counsel in the FDA Chief Counsel’s Office, as well his experience includes a broad spectrum of senior in-house legal work across multiple FDA-regulated industries. Arnie observes:

As a practical matter, it seems as if the only thing Facebook is saying is that if you are sponsoring an “unbranded”, “disease awareness” page, either directly or even perhaps through a third party advocacy group, you cannot preclude an open dialogue of the kind that Facebook is all about it.  If you wish to preclude an open dialogue, then use a branded web site where Facebook will still allow you to disable the dialogue functionality.  If you choose to go unbranded, then you can’t disable that functionality.  Why all the hulabaloo?  In other words, it seems that Facebook is simply saying that pharma can’t have it both ways.  If it wants to go “branded”, then by all means, disable functionality.  But if you want to go “disease state”, “unbranded”, then you are not engaged in active pharmaceutical promotion in any event, so what is the underlying logic of disabling dialogue functionality?  Sounds eminently reasonable, but it does cause one to wonder whether Facebook came up with this position itself or whether there was some influence, direct or indirect, from FDA.  Time will tell.

So, between branded vs. unbranded, which is better?

In a recent study published in Health Marketing Quarterly, “Nonbranded or Branded Direct-to-Consumer Prescription Drug Advertising—Which is More Effective?”, researchers found that non-branded ads compared favorably with conventional ads for specific branded medications. As they observed:

Consumers’ level of disease state involvement was the strongest determinant of attitudes overall and within the two ad groupings, as highly involved consumers had significantly more positives attitudes regarding the nonbranded ads. Regardless of involvement level, however, nonbranded ads maintained positive attitude levels.

Extended to the Facebook issue, the non-branded wall is more likely to be perceived better than the branded wall. This seems to make intuitive sense. After all, unbranded projects the image of just being concerned about the disease-state and branded just about the product — and understandably that non-branded will be received more readily than the branded.

Perhaps unwittingly the new Facebook policy will lead pharmaceuticals to look at non-branded as a preferred option over branded. What do you think?

2 Responses to “What the new Facebook policy tells pharmaceuticals about branded vs. non-branded programs”
  1. dialdoctors says:

    Pharmaceuticals are missing the point of social media. Social media is where brands, unbrands, regular joes and their brother come together in a leveled playing field. Facebook, like all other social media platforms, should always allow conversations. I agree with your assessment that by disabling comments, pharmaceuticals are sticking their heads in the sand hoping everything will go away.

    If someone talks about off-label usage then use the opportunity to explain how that specific drug hasn’t been approved by the FDA to be used in that manner. Maybe even show research studies (if available) explaining why it may be dangerous. Discourage other people from using the drug in such manner without talking to their doctor and figuring out if that would be a viable option for them. They could even market other products which could help that patient with that situation. Say someone is using an antipsychotic in order to sleep but the pharmaceutical has a sedative. Ask them to consider using that one and maybe even offer a sample.

    Comments and conversation is what keeps people informed. Pharmaceuticals aren’t doing anyone any favor by having a one-sided conversation.

  2. Michael Wong says:

    “Dear Pharma Brands: No One ‘Likes’ You” provides an interesting perspective on this issue — http://www.mediapost.com/publications/?fa=Articles.showArticle&art_aid=152165

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