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Facebook Announces Official Changes to the Pages Platform

As many of you know, we currently have the ability to disable comments on our branded and unbranded Facebook Pages, in order to adhere to current FDA rules and regulations.

To follow on our recent update regarding upcoming changes to Facebook Pages, we received word from Facebook about commenting changes that will take effect beginning today.

These changes will affect your Pages in the following ways:

Unbranded Pages

• Facebook will no longer allow administrators of new healthcare industry Pages to disable commenting on Wall posts that are shared with fans.
• Additionally, existing unbranded Pages that currently have commenting disabled on wall posts will no longer have this entitlement after August 15th, 2011.
• This change affects the following types of Pages:

* Community Page X

* Community Page X by Drug Y

* Drug Y Community

* Drug Y Scholarship Program

* Pharma Company X

* Pharma Company X Careers

Branded Pages

• Subject to Facebook's approval, Pages solely dedicated to a prescription medication may (continue to) have this commenting functionality removed to ensure adherence to current FDA regulations.
• Branded Pages must meet the following requirement to receive this functionality:

* Page names that include the drug name (or drug name and a brief description of the drug) for example “Drug X” or “Drug X: Clears Up Symptom X”.

* However, please note that disabling comments will not be approved if the intent of the Page is to foster a community, regardless of whether or not the drug name is included.

Facebook explains that these changes are part of an effort to foster authentic, engaging, two-way dialog with patients, caregivers and healthcare professionals on their platform.

Both your CCC account teams and our contacts at Facebook understand that these changes may lead to a re-evaluation of your strategy and presence on the platform.

As a group, we are committed to helping our clients navigate this transition and have developed the following recommendations for your Pages:

• On August 15th, existing posts on the unbranded Pages will begin to appear with a field for users to comment. If applicable, Facebook can support Page migrations from the original Page to a brand new Page with the exact same name, but will not carry over any other existing content – only the Fan connections. This would be an alternative to manually deleting or editing existing posts that you would not want users to be able to go back and comment on in the future.
• If your brand already has a community-focused page, you can keep the Page in existence but also develop a new prescription drug-specific Page that is compliant with the guidelines above, for which Facebook may disable commenting upon request. The prescription drug Page could then be prominently featured in the left-column of the community Page under “Featured Likes.”
• Create a Custom Wall: Comments are disabled and the Fair Balance is displayed prominently on the Wall. The downside is that Wall postings will not appear in user newsfeeds and fans will have to visit the Page itself to see updates.
• Create a Custom Wall: For which comments are placed in a moderated area (not viewable publicly) and a community manager must approve or reject them manually. The downside is that Page postings will not appear in user newsfeeds and fans will have to visit the Page itself to see updates; transparency and communication when comments are rejected are key.
• Allow comments: Implement a Content Management System to collect comments, and create a transparency/disclosure statement on the Page with clear “do’s and don’ts,” noting that comments will be moderated and potentially deleted if they do not adhere to the guidelines. Transparency and communication about when comments are deleted are key – this option sets up the potential of monitoring a page 24/7 as comments would first appear on the wall and need to be manually deleted.
• Allow comments: Create a transparency/disclosure statement on the Page with clear “do’s and don’ts,” noting that comments will be moderated and potentially deleted if they do not adhere to the guidelines. In addition, utilize the profanity filter and moderation block list to prevent product or treatment mentions in comments. Transparency and communication about when comments are deleted are key – this option sets up the potential of monitoring a page 24/7 as comments would first appear on the wall and need to be manually deleted. Also, the profanity filter and moderation block list are not guaranteed to block all unwanted comments or treatment mentions. Finally, you would need to set up escalation and standard operating procedures internally to manage any issues from the open wall.

ISI (Important Safety Information)/PI (Prescribing Information) Visibility

• In March 2011, Facebook introduced a section in the left-column of Pages beneath the Profile picture which allows companies to reference an ISI. This section pulls from the “About” section of the Page's “Info” tab and will show up to 75 characters by default, with a “See More” link if more than 75 characters. When “See More” is clicked, this section will expand to display more text.
• In parallel, Facebook is introducing additional space at the footer of the Wall for disclosure of this information, similar to the disclosure seen on Facebook Community Pages under “Source.”
• Any custom third-party tabs built for your Pages can continue to be customized with ISI or other content as necessary.

We will continue to follow up with Facebook and provide updates as necessary.

Want to know more?

Please contact us if you have any questions or need any further information.

Ritesh Patel | Bryan Kaye