While a new Facebook policy change has led some pharmaceutical companies to leave the social networking site, many medical device firms continue to stay connected.

Facebook used to allow pharmaceutical companies to submit a request to Facebook to disable the function that allows people to leave a comment on a Facebook page.

But starting Aug. 15, Facebook no longer allows pharmaceutical companies to block public comments on their Facebook pages; the one exception is pages devoted to a specific prescription drug, which are allowed to continue blocking comments.

A Facebook spokesperson said the policy change was made "in an effort to encourage conversations between brands and people" and to promote "an authentic dialogue on pages."

The new Facebook policy for drug companies is interesting, but doesn't affect medical device firms, said Garry Clark, director of public relations for orthopedic device maker Zimmer.

"It definitely makes sense to make comments mandatory given that social media is designed to be an interactive form of discussion," Clark said in an interview.

In reaction to the policy change, some pharmaceutical companies have closed their Facebook pages.

Diversified pharma/device/consumer products firm Johnson & Johnson closed four of its unbranded pharmaceutical pages about certain disease states, including ADHD Allies, ADHD Moms, Fit In Your Skin (about psoriasis) and a New Way for RA (about rheumatoid arthritis), the firm said.

"The decisions to close communities were difficult, but necessary. The new policy altered functionality in ways that changed our ability to sponsor some pages due to regulatory, legal and other considerations," J&J spokesperson Bill Price told "The Gray Sheet."

However, the policy did not impact the majority of J&J's 60 Facebook pages, including the firm's corporate page, which has always allowed public commenting, Price said.

Device Firms Have Mixed Views On Comments

Although the new Facebook policy wasn't directed at medical device firms, some device companies have taken initiatives on their own to either closely monitor or, in some cases, delete all of the public comments on their Facebook walls.

A company's best approach depends on what it wants to get out of being on Facebook, Sam Barnes, director of public relations at Axon Communications, a health care consulting firm based in the U.K., said in an interview.

"It can't just be a broadcast. You have to balance between the risk of negative or unwanted comments and the end-user experience. The public wants to have a positive user experience in the way they interact with a company page on Facebook. Some of the ways that you restrict unwanted comments change that user experience," Barnes said.

For example, orthopedic device maker Biomet manually deletes all public comments on its corporate Facebook page, but allows users to interact by enabling them to "like" company posts on the firm's wall.

Biomet explains its policy to Facebook visitors in a May 4 post: "Our apologies to anyone posting comments. We have commenting turned off for legal and compliance reasons, but Facebook still allows them to go through. All comments will be deleted as soon as they are posted."

Barnes said Biomet's auto-deletion method of controlling comments "is not really the essence of what Facebook is about in terms of social openness. As a user, why do you want to follow a page if when you add a comment, it's automatically deleted?"

Meanwhile, other firms allow comments to appear on their Facebook pages, but they monitor the comments closely and delete those they deem inappropriate.

Zimmer launched its corporate Facebook page this May and allows comments on its page in order to interact with its customers.

"One of the core benefits of using social media channels is that they allow for additional engagement with our customers and their patients. Not allowing comments on the sites misses the point; the channels are not designed for a one-way information flow," Zimmer's Clark said.

He said Facebook has been a "new and exciting vehicle" for the company to communicate with stakeholders, including surgeons and patients.

"We are keen to explore different ways we can share information in a safe and controlled manner. Facebook fits into this philosophy," Clark said. "The reaction so far has been very positive, both within the company and from other Facebook users."

Nevertheless, Zimmer monitors its Facebook page around the clock in order to remove any comments "that violate the conditions of our disclaimer," Clark noted.

Medtronic also allows comments on its company-sponsored Facebook pages.

"Authentic dialogue involves reciprocity and an exchange of ideas between the company and its stakeholders, and this kind of transparency has always been viewed by us as an important advantage offered by Facebook," said Medtronic spokesperson Steve Cragle.

But like Zimmer, Medtronic has a rigorous system for monitoring comments.

Monitoring For Regulatory Purposes

Device companies that allow comments must be prepared to address comments that report product-related adverse events or off-label-use information, Barnes said.

At Zimmer, Clark explained, well established processes are in place to address Facebook comments related to adverse events or off-label promotion.

Likewise, Medtronic has social media experts embedded at the corporate level and within its numerous business divisions to ensure compliance and appropriate use, Cragle said.

"We rely heavily on other, many commercially available, non-Facebook tools for listening/monitoring and auto-alert notification," Cragle said.

AdvaMed's view is that each company needs to decide how to participate in different social media tools like Facebook, while continuing to follow FDA regulations.

"The decision is up to each company as to which communications they wish to make available to the public and assuring compliance with any applicable regulatory requirements," said Khatereh Calleja, AdvaMed VP of technology and regulatory affairs.

Axon Communications' Barnes said there are several ways companies can monitor their Facebook pages, including having company employees manually monitor the page, using Facebook's auto-filtering system for automatically deleting certain comments, using email notifications to monitor comments or setting up a system to automatically delete all comments.

Another less common option is to create a "custom" Facebook wall that relies on a software application that mimics the Facebook wall, but allows the page owner to filter comments by putting them into a holding zone while they are moderated.

The drawback of this last option, said Barnes, is that it limits the user experience by imposing a time delay before the user's comment appears.

Overall, Barnes said, "Most of the health care companies are allowing comments in real time. I suspect they are using the auto-filtering within Facebook in some way and moderation on their pages."

Still Awaiting FDA's Social Media Guidance

FDA is developing draft guidance on Internet and social media promotion of regulated medical products, which was due out in 2010 and then postponed until early 2011. But the wait continues. (See "Also see "To Tweet Or Not To Tweet? Social Media Marketing Guidance Is There If You Look For It, Experts Say" - Medtech Insight, 2 May, 2011." - "The Gray Sheet" May 2, 2011. )

FDA's delay in issuing the guidance is preventing some device firms from joining Facebook and other social media sites, said Jeffrey Senger, an attorney at Sidley Austin LLP and former FDA acting chief council.

"Lack of clarity from FDA on its expectations in the social media arena is making some companies reluctant to participate in this space. There is a cost to FDA's delay, as social media provide useful ways to communicate important public health information to consumers," Senger said in an interview.

There are also concerns that by the time FDA finally issues the social media guidance, it may already be outdated due to the rapid evolution of social media technology.

"That's a challenge for every regulatory body in dealing with technology on the Internet because things are moving at light speed," Gary Kibel, an attorney at Davis & Gilbert LLP, said in an interview.

"Anybody who's going to propose any standards or guidelines needs to recognize that the minute they issue those guidelines or regulations, they may need to be updated in a very, very short period of time."

- Rebecca Kern (rebecca.kern@elsevier.com)

[Editor's note: This story appears courtesy of the editorial staff of 'The Gray Sheet,' your source for coverage of devices and diagnostics. For a free trial, call customer service at 800-332-2181.]

As Some Pharma Companies Exit Facebook, Device Firms Stay Connected

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