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 ComScore should 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.