Author: Stacey Homan
Creating a Facebook page is quick and easy. And with Facebook slated to be bigger than Google in just a few years, the time is now to start developing plans to create a Facebook page for your brand to engage and inform your customers who are already online:
- 72% of US adults (169 million) are going online for health information.
- 250 million people are on facebook EVERY DAY.
- Facebook accounts for 25% of all US pageviews.
So, here is a quick checklist to starting a fan page on Facebook for pharma and medical device companies:
- MESSAGE, NOT MEDIUM – With the lack of social media guidelines, remember it’s the message, not the medium. Until the new guidelines are issued, the same rules apply to Facebook as apply to sites elsewhere on the internet. The recent Novartis warning letter clarifies and reinforces some of the already-known guidelines regarding online promotion: don’t go off-label. Include risk information. If you are a pharmaceutical company, widgets need to be submitted 30 days prior. Note the warning letter did not have issue with the widget/pages themselves, rather the message.
- TRANSPARENCY – you owe it to your patients to be transparent as to who is sponsoring the page. Disclose everything: conflicts, majority sponsorship, editorial control. Take the best of journalistic practices and apply.
- COMMITMENT – it will take time to gain followers and fans of your page. Designate a person or group who will be consistent with updating the content. Start weekly for a month or two to iron out any kinks and move to daily. If you decide to stop the project, the page will need to be completely deleted.
- REGULATORY SUPPORT –There needs to be a framework in which to operate the page in your procedures and review committees – reviews, approvals, oversight and audits as well as timely response to comments. Check out Elsa’s ‘Safe Driving in Social Media’ postings (part 1, part 2, part 3) for an overview of regulatory concerns and solutions.
- QUALITY COMPLIANCE – be prepared for negative comments and how you will respond to them, paying careful attention to the potential for patients to describe device or surgical failures. They may need to be reported to your quality department for further review to determine if they are feedback, complaints and/or reportable MDRs. The above mentioned warning letter also mentioned that the initial, company-sponsored post would be subject to FDA guidelines, but not the comments made by patients.
It’s important to remember that communicating with patients through Facebook is a new concept and there will be a substantial amount of figuring out just how this new medium works best with patients and stays compliant. There will be ideas that work; there will be ideas that don’t. But failing to notice the trend lines that are occurring within the online space would be doing your marketing department and patients a disservice.
On a side note, GoodPromotionalPractices.com is launching a Facebook page of our own. You can use it to keep up to date on the latest information, give feedback, ask questions and network with fellow industry professionals as well as post relevant job openings.