Pharmaceutical companies have begun creating a presence on Facebook characterized by control and caution. Why? Despite unclear regulations in the U.S. governing their presence online, they may still be penalized for marketing materials on the Internet. The result is, in terms of their Facebook marketing content, a mixed bag of sometimes disingenuous Pages and Groups, fluffy applications and tightly-controlled discussions.
In November of 2009 the U.S. Food and Drug Administration (FDA) hosted a hearing to examine this very issue: how to regulate drug companies’ marketing online — including social networks, blogs, podcasts, Wikipedia, etc. More than 800 parties tried to register to speak at the two-day hearing that included 69 speakers and 77 scheduled presentations; most attendees were either pharmaceutical or marketing reps, and the rest were a tiny fraction of consumers, non-profits and consumer advocacy groups.
According to the FDA, which regulates the promotion or advertising of pharmaceuticals in that country: “The continually evolving nature of the Internet, including Web 2.0 and social media tools… have raised questions and concerns over how to apply existing regulations to promotion in these newer media.”
Currently there are no laws governing what pharmaceutical companies may or may not do online — aside from the general expectation that they disclose risk information alongside drug benefits. The last time the FDA broached the subject was 1996 and has since been based on guidelines for print marketing: where both benefits and risks of drugs must be presented side-by-side.
“The worry is the drug companies will find a way via the much more malleable and fluid environment of the Internet to promote their product in one-sided ways — and that’s not good,” said Steven Findlay, a senior health policy analyst with the Consumers Union who spoke at the FDA hearing. Facebook Pages for or by drug companies ought to include benefits and risks of drugs, he said, and be regulated by the FDA.
Several drug companies we saw on Facebook tried to mediate the info shared on their pages by closing their Walls, disallowing comments/likes and keeping consumers’ comments to a minimum by wielding tight control over Discussions.
The Facebook pages of Nexium (marketed to relieve heartburn caused by acid reflux disease) and Claritin Eye (eye drops for allergies) both closed off their Wall post to comments and likes. Both pages include information available on their product web sites.
“If they have a Wall, they can’t control what’s on it. If people complain about Nexium, then they’d either have to try to censor it, which would be potentially a problem, or they’d have to spend time responding to it,” said Diana Zuckerman, President of the National Research Center for Women and Families. “I would say to anyone who wants information about a medical product: Facebook is not the place to get it.”
Zuckerman testified at the FDA’s November hearing and said companies creating Facebook pages are likely to present information in such a way as to highlight the benefits without prominently pointing to the risks. Charging companies a fee payable to the FDA to monitor these sites would be the ideal way to ensure this doesn’t happen, she told us.
Claritin’s page has 6,600 fans and no place for comments, whereas Nexium has 508 fans and controls discussions by employing an app users have to allow access to before posting comments or questions. Nexium’s Facebook admin closely monitors these discussions, posting answers to questions or referring people to more information on Nexium’s web site.
Additional information on the pages include tabs for frequently asked questions, product information and risks, product savings programs, community guidelines for Facebook users (e.g., no obscenity or defamatory language) and tips.
Prevacid 24HR is another heartburn medication that had 8,000 fans on Facebook but took a radically different approach to its presence there than Nexium. Comments and likes are allowed on Prevacid’s Wall, although there were no active Discussions, and they even offered a coupon for discounts on their products.
There’s no penalty for misrepresenting information about a drug on Facebook, explained Zuckerman, although there is such a fine for similar misrepresentations in traditional media. What’s happened online is that pharma companies will present risk information, but it may not be where a user is likely to look, she told us.
“I think that, at the very least, these companies should have all of the same risk information that they’re required by law to include in television ads and magazine ads,” she says, noting that the unlimited space on the Internet would make this easier for the drug companies to accomplish.
Another tactic pharmaceutical companies are employing on Facebook: customized apps. Claritin’s page employed one, albeit the app was not closely related to the product. Claritin Eye Makeover allows users to upload photos of themselves to change and edit their eye color. Johnson & Johnson’s Acuminder, with 511 fans, is an app that reminds users when to change or purchase contact lenses, as well as remind them of their next eye exam.
Some companies also offer a Page or Group around a cause related to a drug. This is an especially gray area. Some examples we looked at clearly disclosed their sponsor relationship while others didn’t — either way, it appears that companies can be liable in some circumstances.
A Page with almost 109,000 members called Take A Step Against Cervical Cancer has ostensibly organized around preventing cancer — doing so by vaccinating young women with the HPV vaccine Gardasil, made by Merck. The Wall is practically non-existent, although there is information about side effects and links to Gardasil’s web sites on the page. There’s also an interactive fact book and quiz, and an app that allows users to make their own symbol against cervical cancer to post to their Walls.
Although rallying more than 100,000 people around a cause like cervical cancer and hiding the connection to a pharmaceutical company on the Info tab is not entirely a deception, but it’s also not transparent. Some similar Pages take this a step further.
Epilepsy Advocate, with 4,300 fans describes its Page as, “a community of people living well with epilepsy, their family members, and their caregivers. Epilepsy Advocates are people just like you who have shown the courage to share their stories and provide support to others.” Nowhere on the page, however, does it note that Epilepsy Advocate is a program sponsored by the pharmaceutical company UCB, which makes drugs for the treatment epilepsy. Although there are no strict laws governing pharma on social media, is it legal to promote an organization sponsored by a drug company without saying so?
It’s a slippery slope.
In UCB’s case, the Page itself is not currently illegal; however, the company is also responsible for the content. If a “user reported an adverse reaction to its treatment there, UCB would need to report it to the FDA,” according to an analysis by Adweek from December. “What’s more, pharma companies can be held liable by regulators for people discussing off-label use of their products on their sites.”
ADHD Moms, a Page for mothers of children with Attention Deficit Hyperactivity Disorder, is similar to the epilepsy page, but discloses on the Info tab that its page of 9,500 fans is sponsored by McNeil Pediatrics, a self-described leader of ADHS treatment with its Concerta drug. Disclosure about the Page’s sponsor is a good thing, but the implicit promotion of pharmaceuticals via an advocacy group walks a fine line.
It’s a complicated issue, said Findlay of the Consumers Union, because pharmaceutical companies have previously walked this fine line between providing useful information and hiding their sponsorship of it. Pharma companies are legally required to disclose such information in advertisements offline and, after years’ worth of reprimands from the FDA for not doing so, they’ve gotten the message, Findlay said. The way this message translates to the online world has yet to be seen.
Findlay tells us that a draft of regulations or guidelines for online marketing could come this year with a final ruling within two years. These regulations will most likely clarify the full disclosure of risks/benefits issue, he said.
“One should never make the mistake of underestimating the capacity, the resources and the willingness of companies to really aggressively marketing their products and to walk a thin line obeying the regulations,” he says. “They’ll go right up to the point where they don’t want to cross into illegality — but they come close.”
Facebook Chat, the company’s instant messaging system, has already been live on other sites, like Meebo, for more than a year. But now it’s coming to the granddaddy of IM: AOL’s AIM. Starting now, you can log in to your AIM account — whether your use the Windows or Mac desktop clients or the web-based version — then log in to Facebook using Facebook Connect.
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