The fact that Facebook’s new policy going into effect August 15th – where admins of pharma pages will no longer be able to disable commenting (with the exception of branded Rx drug pages with fair balance and ISI) – has been well covered in the press. Go here if you need a refresher.

Rather than writing about the mechanics behind the move, providing advice to brand managers or agencies that are pulling their hair out trying to work around the inevitable, I thought I’d focus on why the new Facebook policy should NOT impact your brand.

That statement might sound a bit odd, but if you created your Facebook strategy correctly, the August 15^th change shouldn’t impact you at all for two simple reasons.

1. You already know your pharma brand pages shouldn’t expect to be ‘liked’ because it goes against the psychosocial behavior of patients. We published a post previously on A Different Perspective about the challenge of getting patients to reach the point of acceptance, that their lives are forever changed upon diagnosis of a chronic disease, and they are living a ‘new normal’. Do we really think they’re going to declare public support for a medication that’s helping them hide their condition from public display, or not continually remind them they have the disease? Consumers may feel gratitude the medication is available, they may feel better physically taking their medication, but do they ‘like’ it? No. It’s a continual reminder that they are flawed in some way and must take their medication to achieve their ‘new normal’. Regardless, you don’t have anything to fret over in August, because your pages are exempt. And, the good news is there are a few recommendations for how you can create greater engagement and a reason for people to like your Page farther down in this post.
   
2. You’re already ahead of the curve and have a social media policy in place that allows for open commenting. Yes, I said it. You’re progressive enough to have processes and procedures in place to respond to off-label discussion and have a solid system (and resources) for following up on potential mentions of adverse events. I’ve never seen a company receive a warning letter for honestly trying to do right, responding appropriately, being transparent and doing it’s best to comply with existing regulations.

With the August15^th change looming, the position you’re in may well be water over the damn at this point. Here are a few suggestions that might help never put you in this position in the future.

For Product Brand Pages
Develop a content strategy that appeals to the Facebook audience. You’ll probably still have commenting turned off, but your content strategy should give the audience as much value as possible. Build into your Page interesting, dynamic and responsive interactions like:

• Video stories from real patients (not canned scripts and hired actors)
  
• Provide patients with access to co-pay cards/discounts (who isn’t interested in saving money in this economy?)
  
• Link to your patient support programs (the Facebook Universe is enormous. If people are seeking support, help them find it)
  
• Repurpose your valuable assets and make them available (take all of the assets you worked so hard to create an provide a way to access the via the Page)

Are you going to see a huge bolus of ‘likes’ when you alter your brand Page? Probably not, but it also won’t cost you a fortune to capture a few thousand extra ‘likes’ and enrollments in your patient support programs – driven largely from the assets you’ve already created. Go here to visit the TOBI Page and see an example from Novartis that is moving that direction.

For Disease State/Lightly Branded Pages
Open commenting is coming (in less than two weeks), so you need to deal with it, understand the psychosocial behavior of the Facebook audience and build your social currency. Here’s a few things to think about when developing your next strategy:

• Establish your social media policy and rules of engagement. Without clear internal guidelines, you can’t effectively develop an external-facing strategy. Take the time, consult experts, get it documented and internally approved. We’re getting more social by the day, so time is of the essence.
  
• Give people a reason to ‘like’ your Page. Give them value. Provide them support. Offer up exclusive access to a coupon by participating in an interactive activity, or host an upcoming event.
  
• Engage in the conversation. With your social media policies in place, engage in the conversation. Monitor the conversation and interject where required by present regulations. Do your best to follow-up on what might be an adverse event and provide a link and phone number to the FDA site to help consumers report side effects they may be experiencing. Put the processes and people in place to do this right. Your consumers and bottom line will appreciate it.
  
• DON’T create a faux experience. In my opinion, creating a “custom wall”, that does not allow commenting goes against the intention of Facebook. You need to align your content and strategy with your visitors’ expected experience. If you look at your strategy and think you can’t do that, then you probably shouldn’t invest in building a Facebook Page.

The Final Word
View the August15th deadline as a wake up call. Unless you own and fully control your digital property, you’ll always be subject to policy changes of others. When building digital strategies keep this in mind and also don’t lose sight of your customers and what they want/need. Give them support, provide them value, and do it on their terms.
If there’s anything I’ve missed or you want to continue the debate, leave a message in the comments or contact me directly.

By Kurt Mueller, Chief Digital & Science Officer