Facebook recently rolled out new “Premium Ads” that allow brands to leverage page content to engage with both fans and non-fans. These ads are highly social and interactive, and will influence the way that marketers in all industries use Facebook. For the the pharmaceutical industry specifically, these Premium Ads have implications in terms of FDA compliance, including decreased control over open fields, off-label or adverse event–related comments, and potential exposure of a patient’s health condition. Despite these challenges, the new ad formats offer a better platform for social engagement—pharma can continue to utilize Facebook by following some guidelines, and by leaning toward unbranded rather than branded content.

1. Highlights
Facebook Premium Ads:
 Facebook recently announced
Implications for
the launch of Premium Ads. Pharmaceutical Marketing
By: David BenBassett, Ruth Lim and Remy Wainfeld, Lian Han and Sara
 The new ad units enable Collis
brands to use the content they Digital Integration & Innovation, RTC
post on their page as the ad unit. March 2012
 The premium ad units will Summary
Facebook recently rolled out new “Premium Ads” that provide
appear on a user’s Facebook
marketers with the opportunity to engage with both fans and non-
homepage, integrating seamlessly
fans through interactive content drawn directly from their brand
into the user’s news feed. pages. The new Premium Ads are highly social, allowing users to
“like” and comment directly on the ad—these interactions are
 The ads are highly social, then posted on friends’ news feeds as well as on the advertiser’s
allowing users to “like” and brand page. These changes will influence the way that marketers
comment directly on the ads. in all industries use Facebook, but for the pharmaceutical industry
User comments and “likes” will specifically, these Premium Ads have implications in terms of FDA
subsequently also be reflected on compliance, including decreased control over open fields, off-label
the advertiser’s page. or adverse event–related comments, and potential exposure of a
patient’s health condition. Despite these challenges, the new ad
 Pharmaceutical marketers can formats offer a better platform for social engagement—pharma
can continue to utilize Facebook by following some guidelines,
leverage the new features of the
and by leaning toward unbranded rather than branded content.
premium ads to better engage
and understand their target Key Information
audience. On February 29 at an invitation-only conference for marketers,
Facebook announced a departure from traditional advertising and
 However, pharmaceutical the introduction of new Premium Ads. The functionality of the
marketers should manage their new ads puts more “social” in social media advertising. They differ
content closely to avoid FDA from past Facebook ad units by extending reach and impressions
violations, as the new format across Facebook users, even those that are not fans of a brand, by
allows for open-field comments providing more room for interaction, “likes” and comments, and
and potential exposure of a by offering more ad formats than before.
patient’s health information.
The new formats feature content drawn from a brand’s page
posts, and will appear in a user’s news feed and on the right-hand
side of the Facebook homepage. Marketers can now choose from
six different formats: Photo, Video, Question, Status, Event and

2. Link. Depending on which ad format they choose, marketers have between 90 and 150 characters of
text to work with in each ad. The biggest change related to these new formats is the way in which they
will be served up to Facebook users, and the way the content of the ad is formulated. For example:
 Brands can now choose to promote content that is drawn directly from brand posts on their
page, rather than ads that are independently written. This changes the art of ad copywriting, as
ad copy and post copy are now one and the same.
 Ads will show up on the news feed of fans as well as those who are not fans but have a friend
who has taken action on a page (“like,” comment, share, check-in, claim an offer, etc.). This
expands reach and socialization of a brand’s content.
 The larger format will show users which of their friends (pictures and names) have already
“liked” the advertiser, exposing users’ preferences and habits to others.
 For people who have already “liked” the page, the ad will include an expanded interface that
will allow them to like and/or comment directly from the ad. The “likes” and comments will
subsequently be reflected on the brand’s page.
Photo: Courtesy of Facebook
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3. Implications and Action Items
As advertisements on Facebook become increasingly social, this poses greater challenges for
pharmaceutical marketers to advertise on Facebook without running the risk of violating FDA
compliance rules and compromising patients’ privacy. By disseminating brand page content as
advertisements, the new format exposes brand content as well as accompanying user comments to a
greater range of audiences, making it difficult for brands to contain discussions within the walls of their
brand page. Open-field functions in the new format lend themselves to the risk of off-label and adverse
events mentions in comments, and the increased distribution of the ads themselves across Facebook
users increases exposure of a patient’s health condition, creating potential ethical implications. These
issues and suggested action items are outlined in the chart below.
Facebook Changes and Implications for Pharmaceutical Marketers
Old Format New Format Implications Action Items
 Advertising  Ad content drawn  Branded content no  Strategically select posts that comply
copy written from posts directly longer only confined with existing FDA regulations on
independently from advertiser’s to brand page advertising
from Facebook brand page  All content must present fair balance of
page content risk/benefit information and avoid
unsubstantiated claims
 No “likes” or  Users can “like” and  Open fields lead to  Carefully yet respectfully monitor social
Comments comment on the ad less control over activity and comments on the ads
on ads directly user-generated  Inform users of the legal limitations and
 Brands no longer conversation, implications of their communications on
allowed to disable including potential the brand page and warn them of
comments on their off-label and adverse potential comment deletions
page posts and ads1 events comments  Content should direct conversation
away from possible FDA violations
 Provide MedWatch and Contact Us
information on Facebook page/ad
 User’s  User’s interaction on  Increased exposure  Rather than using premium ads as a
interaction on the brand’s ad will of the condition of way to reach new consumers, use them
brand pages appear on their patients who interact to encourage existing fans to interact
and ads is kept Facebook friends’ with the brand page with the brand via Facebook by limiting
private news feeds  Increased chances of promoted content to be viewed by
 Ads include names non-stakeholders fans only
and photos of the participating in  Consider using unbranded content only
user’s friends who discussions
have “liked” the page
 Text and image  Six different formats  Multimedia may help  Consider using unbranded content only
only advertisers can with including fair  Ensure all content includes fair balance,
choose from (Status, balance, but including multimedia and all copy
Photo, Video, character limits may
Question, make fair balance
Event, Link) compliance difficult
 90-150 characters
1
Pharmaceutical marketers with Facebook pages have different privacy options than other marketers, and at this time it is
unclear how that may change with the introduction of the Premium Ad format.
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4. However, despite the many challenges, the new ad formats present opportunities for pharmaceutical
marketers to better engage their audience. For example, the Premium Ads place the brands’ page in
the spotlight like never before, extending their content to a new and expanded audience. The ads
enable marketers to step outside traditional text and links, and include photos, videos and
questionnaires in their ad content.
Premium Ads are also more cost efficient: By using content from the brands’ pages as the main content
of the new premium ads, Facebook simplifies and cuts down the process of ad creation. Marketers can
now quickly and easily alter and improve their ad content according to the feedback and response they
get from these new ads.
Finally, Premium Ads provide marketers with valuable insights about their target consumers, as “likes”
and comments can now be analyzed in regards to the ad unit (and the ad’s content) itself.
Conclusion and Final Thoughts
This all having been said, the new format does require more strategic thinking as marketing content
becomes more portable and reach more expansive. Marketers need to carefully manage the
relationship between their Facebook fan page and what content is being redistributed in the ad units,
as well as monitor user engagement, feedback and ad performance to optimize content management.
Additionally, there are some key strategic topics that pharmaceutical marketers should consider
discussing regarding the new Premium Ad formats. These are as follows:
 Consistent brand image. Any disconnect between the brand’s Facebook communications and
other platforms will be more obvious than before. Marketers should ensure that advertising
content across platforms offers a consistent image and personality.
 Consistent management. Marketers should consider the resources they have to manage their
Facebook page, since it is now inherently social media and advertising at the same time—
marketers now need to actively monitor user comments and interactions on the brand’s
Facebook page and ads, as well as have more reason to keep their Facebook page heavily
engagement oriented.
 Analysis matters. By analyzing users’ interactions (e.g. “likes,” shares, comments) with ad
content, marketers can better understand users’ preferences and better tailor future creative
and copy strategy to appeal to their target audiences.
 Unbranded is better. While the FDA has never entirely addressed social media in its guidelines,
the Premium Ads expose a brand’s content and a user’s privacy more so than before.
Unbranded efforts provide a wider safety net than branded efforts, and eliminate the need to
work within the constraints of fair balance.
 Engage with richer media. The upgraded premium ad formats enable brands to better
communicate and engage with their audiences through a variety of multimedia content,
including traditional text and links, as well as photos, videos and questions. Brands can use the
opportunity to educate their audiences via videos or illustrated diagrams, or better understand
their audiences via polls.
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5. It is understandable that pharmaceutical marketers may shy away from advertising on Facebook in
order to avoid risking violation of FDA guidelines. However, with increased options of customizing ad
content, marketers can now better engage and interact with target audiences on Facebook. Therefore,
we recommend that pharmaceutical marketers who wish to advertise on Facebook restrict their ads to
fans only, and also devote manpower and time to ensure that all content on the site (inclusive of user
comments) does not violate FDA guidelines. Additionally, we urge the use of unbranded content over
branded content across the platform, in order to have more flexibility in being “social.”
If you are interested in discussing the impact of these changes for your particular brand, RTC is here for
you—just contact your Digital Strategist, Account Manager or our Business Development office.
More information on Facebook’s Premium Ads can be found online:
https://www.facebook.com/business/fmc/guides/premium?campaign_id=250393211715997&creative=premium
About the Digital Integration and Innovation Team
The RTC Digital Integration and Innovation team is tasked with keeping track and making
sense of the ever-changing digital world. It’s our job to understand the nuances of how and
why different types of people use technology and what that tells us about them. More importantly, it’s our job
to help our clients apply this knowledge to better communicate with their customers. We help clients translate
business goals into marketing campaigns that build relationships with customers. In the 21st century,
understanding how and why someone uses technology is as important as understanding where they live, what
gender they are, and how old they are. That’s where we come in. From ensuring that digital behavior is
considered in the research phase, to tactical plans that align digital, print and broadcast tactics, we work with
clients and internal partners to make sure it all works.
It’s not about what’s cool. It’s about what works.
About RTC
RTC is a full-service direct and relationship marketing agency based in Washington, D.C., in the heart of
Georgetown, with an additional office in New York. RTC boasts more than 45 years’ worth of innovative,
targeted solutions that grow its clients’ brands and help them forge lasting, valuable relationships with their
customers. What distinguishes RTC is its unique ability to analyze data and research on both a rational and
emotional level, and to leverage insights gleaned from that data to motivate customers and prospects to take
action. RTC’s clients include AARP, Procter & Gamble and Janssen Pharmaceuticals, as well as other major
brands in the pharmaceutical, financial services and telecom industries.
To learn more about RTC, please visit www.rtcrm.com or follow the Twitter feed @rtcrm
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