Much fanfare and “sky is falling” comments have been made by bloggers regarding FDA’s recent warning letter to a dietary supplement maker that used Facebook to “Like” an unapproved claim regarding one of its products (see, for example, “FDA Wants to Regulate Drug Firms on the Internet and It’s Targeting Facebook ‘Likes’” and “What’s Not To Like? Facebook And The FDA“).
Scott Gottlieb — Forbes’ conservative commentator — claimed that FDA is “ramping up its regulatory activity over the use of Internet tools by regulated companies” (op cit). But as my friend Eileen O’Brien said in a recent post: “This warning letter isn’t really about Facebook or blogs, but about following existing guidelines,” specifically guidelines about making unsubstantiated product claims (see “FDA Warning Letter: Don’t Make Unsubstantiated Claims, Even on Facebook“).
But I’d like to point out that the FDA singled out Facebook “Likes” at the exactly the same time that Facebook announced a revision to its News Feed design.
As pointed out by the Wall Street Journal (here and in the video below), “Changes to the feed — the key channel on Facebook’s service where users post and consume content — include a more minimal design, larger images and new types of sub-feeds. The revamp reflects a big push to prod users to spend more time on the site and curry favor with brands hoping to be noticed by Facebook’s users.”
The new News Feed design also allows for MORE text in the summaries. Bigger photos and more room for text are good news for pharma marketers who have struggled with complying with FDA regulations regarding “fair balance” when using online ad services such as Google’s adwords that have limited space (see “Overcoming Space Limitations in Social Media“).
Most of the items in your Facebook News Feed comes from friends and sources related to pages and posts you “liked.” Pharma marketers can take advantage of that and target ads to people based upon their likes. Better yet, if you “Friend” a pharma Facebook page — to download a coupon, for example — new posts to that page may show up in your News Feed.
I may not understand all the technical details of how pharma advertisers can now target specific people via ads in News Feeds, but I see that there is a definite connection between “Likes”, “Friends”, and the “News” you will be served on Facebook. FDA, in my opinion, has also seen the possibilities and its recent letter highlights the fact that it will be looking not only on what pharma “likes” but what messages pharma places in Facebook News Feeds.
Pharma now has more incentives than ever before to accumulate “Friends” and “Likes — it’s not just a numbers game. It’s a targeted advertising game.
While Facebook is offering pharma advertisers the means to create FDA-compliant social media “News,” Google is not doing much to please pharma. For example, it’s new search result format seems to exclude direct content from pharma companies (see “Google’s New Drug Search Result Format: A ‘Knowledge Graph’ that doesn’t include pharma!“).
With regard to the “space limitation” issue, Google devised a new adword format that allowed pharma advertisers to include important safety information (ISI) within the ad. This format was tested by Bayer (see here) and the FDA did NOT issue any warning letters.
So, why haven’t we seen more of these new Google adwords by pharma? That’s exactly the question I asked people at the recent Digital Health Coalition workshop during ePharma Summit in NYC.
One of the issues the workshop was trying to address is how to solve the space limitation problem of social media and Internet advertising so that FDA regulations can be followed (i.e., display ISI). Google’s beta adword format seemed to have solved this as far as search was concerned, so why haven’t we seen more pharma companies use the new format? I have some ideas about that; i.e., the bad blood between Google and HHS/DOJ (see “A Pharma Social Media Conspiracy Theory: Were Guidelines Held Hostage as Part if FDA’s and DOJ’s Criminal Investigation of Google?“).
So far, Facebook has avoided alienating the FDA by encouraging illegal drug sales, which is what Google did. Now that Facebook is cozying up to advertisers and competing with Google for ad dollars, it should proceed carefully with drug advertisers, especially the ones that FDA doesn’t like: the online drug stores.
