Pharmaceutical Social Media Policies: When Drugs and Facebook Intersect

Social media networks, such as Facebook, help businesses build brands, introduce products, and increase overall traffic to their website. Facebook is one of the most highly trafficked websites online, with millions of visitors every day.

But what happens when the product your business sells is a highly regulated prescription medicine? Facebook can be a useful place to market your drug by providing physicians with product-specific indication, prescribing, and safety information, as well as educating patients and caregivers about product dosage and side effects.

Inherent in Facebook is a highly interactive user interface where members are often encouraged to have robust dialogue. Yet, on drug companies’ Facebook pages, patients began posting comments about adverse reactions to products, which drug companies are legally required to report to the Food and Drug Administration (FDA), and comments about off label uses of drugs (when a drug is used in a different way than described in the FDA-approved drug label), which is illegal for drug companies to promote without certain supporting research.

Prior to August, Facebook policy allowed drug companies to disable comment walls on their company pages, which prevented the public from posting or viewing comments. Many companies took advantage of because of confusion about whether the Food and Drug Administration would require companies to report adverse drug events disclosed on social media.

Facebook sent letters to pharmaceutical companies indicating that beginning August 15 they no longer would allow the companies to disable the comment features on pages associated with the drug companies, with the exception of pages for individually branded drugs. Facebook would allow companies to continue to block wall comments on specific prescription product pages, but those are a minority of pharmaceutical company pages.

As a result, reports indicate that some companies, including Johnson & Johnson and AstraZeneca, which have multiple Facebook pages, shut down some of their pages. AstraZeneca U.S. spokesman Tony Jewell said the company will maintain its corporate Facebook page, AstraZeneca US Community Connections. “We strongly believe in using social media to engage with stakeholders. We regularly evaluate the most effective channels available for our use, in keeping with our regulatory responsibilities.”

Johnson & Johnson posted a message on its website that said the majority of its more than 60 Facebook pages were not affected by the change because they already allowed comments. But it decided to shut down several unbranded pharmaceutical pages because “the new policy altered functionality in ways that changed the ability to sponsor some pages due to regulatory, legal and other considerations.”

According to The Washington Post, the FDA has not yet released guidelines for online engagement. A draft was expected by the end of last year, but was then delayed. The agency has said that it will not be providing platform-specific social media policy or guidance, such as guidelines for Facebook walls. Instead, it will provide higher-level principles for online communication.

Social media experts have warned that drug companies that continue their presence on Facebook “may be at future risk until the FDA gives an official ruling on whether customer comments on corporate social media pages can be interpreted as ‘medical advice’ or other types of positive or negative medical endorsement.”

If and when the FDA weighs in online communications, there could be implications for other sectors regulated by the industry, for example medical device and diagnostic companies. Continue to watch the adaptation of social media and the health care industry as they evolve to accommodate not only advances in technology, but also regulations designed to protect patients and consumers.