Community Management In A Regulated Environment

Core components of a successful community management program,  with help from LIAM

Before you even consider the effects and implications of regulations, and of reputational concerns, it’s important to be aware of the four core components of a successful community management program:

Here’s how they work:

Listen, Identify and Align

Before embarking on any kind of social program – before even defining a strategy – you need to activate

social listening in order to identify and understand what your desired community needs, how they  communicate, where they live in terms of social platforms, and what kind of content they respond to (both  positively and negatively). Once you have identified these key components, you can define your community  management objectives and construct a program that aligns both with those objectives, and the needs of  your target community. As a core part of our practice, CMI/Compas uses social listening as the first step in  any social planning, to research what the audience looks like, and which social platforms they are most  active on. This is particularly important in the pharma space, as patients and HCPs use a wide variety of open  and closed platform; it’s critical to identify precisely where your audience lives, as well as what they are  saying, and who the super users might be (along with any detractors).


As you set up and maintain your program, ensure you have effective tools in place to ensure that no

comments are missed, which in the pharma space includes any mention of Adverse Events (AEs). Whether  you use a partner (specialized support from companies such as Mint and Crisp can be particularly effective to  guarantee 24/7/365 AE monitoring, for example), or you handle it in-house, there are many holistic community management solutions (e.g. Sprinklr, Sprout, Spredfast, and even some others that don’t start  with the letter S). Using solutions like these will enable you to develop and automate workflows that cover  sorting, labeling, assigning, and tracking all incoming comments from the community (you can also set up  alerts to notify you of influencer or detractor activity). Such solutions also allows for easy, robust and flexible  reporting options: It’s important to be able to track trends and volumes, both to establish the effectiveness  of your program, and to help scope out future staffing needs. And of course, capturing AEs in real time will  enable you to remain FDA-compliant.

A subset of monitoring is Crisis Management. It’s a critical foundation of any successful community  management program, being particularly fundamental to your reputation management efforts; this is even  more true for pharma social, given the nature of the reputational risks pharma companies can face. It starts  with monitoring, but you need a formal framework for identifying comments that could negatively affect  your reputation and for escalating those comments to a resolution (a tiered approach identifying different  levels of crises can be an effective way to organize a framework). This involves ensuring coverage and the  ability to connect with legal, compliance, PR, etc., in real time. Crises do not tend to stick to regular business  hours; they can also come from anywhere in the world, at any time.

All these components need to be integrated for a full and successful program. Basically, you need LIAM.

Implications of regulation and reputation management

While a core component of building and managing a community is authenticity, which often translates into  tailoring your responses to be meaningful and unique to the person you’re responding to (while still keeping  within the parameters of your brand voice), the impact of pharma regulations and reputation management  concerns must be considered.

Both these factors can be combined into one word: oversight. To ensure the necessary amount of oversight  from the perspective of protecting the brand, the simplest solution can be to create a preapproved list of  “canned” responses that can be deployed as appropriate. While this approach has its advantages – it  eliminates any risk of violating industry regulations, ensures that none of the responses will damage a  brand’s reputation, and increases efficiencies across the board – it also has its limitations.

For example, it seems to contradict the concept of authenticity. How can your brand be authentic on social if  you’re posting canned responses? The answer is that while some “in the moment” authenticity is certainly  being traded for brand safety, in many cases this may absolutely be the correct trade to make, depending on  your objectives for community management, and your tactical approach to protecting your brand.

Strategies to successfully optimize your community management  approach in the Pharma space

Fortunately, there are two solutions to help mitigate this trade, and to successfully optimize your approach  within the Pharma space.

One is to generate a substantial inventory of pre-approved responses, the tone of which can match your  brand and the types of interactions you see from your community, and the variety of which can help  diminish the perception of lack of care (having a community manager adding their initials/name and  otherwise subtly customizing preapproved responses may be possible, depending on whether your internal  review process allows for any type of customization). While having a human choose to deploy the most  appropriate response to a given comment can help ensure a higher level of authenticity, there is an alternate  option: bots. Bots have transcended their original Twitter-based stigmas to become a very valid option,  thanks to the integration of AI with preapproved comment inventories. It’s now very easy to preprogram a  bot solution with multiple potential conversation flows—including blacklisting certain users to avoid  legitimizing otherwise illegitimate responders—and integrate it into a preexisting platform like Facebook  Messenger. It’s not a solution for everyone, but it’s rapidly becoming an ever-more sophisticated tool at your  disposal.

The other option, which the most ideal, but is also more time-consuming, and requires a more real-time  approach from your brand’s PR, legal or reputation management team, is this: Live approvals of all  responses. To successfully manage this approach, several elements are required. Someone needs to be  monitoring the community in real-time to identify appropriate opportunities for unique replies and to craft  brand-safe responses. You also need to create a service level agreement with whoever will be approving the  replies, and ensure that appropriate coverage is in place to meet that SLA so that responses are not unduly  delayed by waiting for live approvals. While this adds more steps and therefore more friction to the process,  it’s a great way to keep all replies engaging, which contributes to building loyalty, trust and advocacy within  your community. And, of course, it also eliminates risk as no reply can be published without the necessary  approvals.

One size fits all?

Worth considering: Do you want the same approach for all types of interactions? Or do you want a more

nuanced tactical structure, where service-related interactions are handled in a different manner from more  soft-skill based, general interactions? For example, as a brand you may decide that someone complaining  about a particular aspect of your service in need of active resolution may require a more real-time,  personalized approach than someone simply saying they love your brand… or vice versa.

For the service-related interactions, the decision revolves around whether you want to attempt resolution  on- or off-platform. The majority of the time, off-platform is the most brand-safe way to go, as it takes the  interaction out of the public view. This typically involves requesting the user call or email for more  personalized service. In this instance, canned replies may well be appropriate since you’ll simply be providing  a point of contact for the user. However, to mitigate the impression that you are not engaging with them or  caring, you could pre-approve multiple variations on the theme of apology/empathy plus new point of  contact. This would help keep your interactions looking more authentic and less repetitive.

Alternatively, you might decide that the softer types of engagements would be best handled with a series of  preapproved response (Thanks! Awesome! We love hearing that! etc.), while any kind of problem resolution  would be more suited to the real-time approval approach.

Ultimately, it may simply be more efficient to preapprove everything. Volume of interactions, the split  between service and soft, how your community chooses to interact… all these factors play into the decision.

But the good news is, there are a number of ways to optimize a community management program to meet  your goals within the heavily regulated Pharma space.

Getting started

Once you’ve made your choices, it’s time to build out your program from the ground up. Define your  objectives for the program clearly. Create your SOPs, which will involve mapping out each step in the  community management process, including: creating community guidelines for users, determining the  personnel involved and each step they’ll need to take when reviewing, assigning, investigating and  responding to questions, how other groups such as PR, legal, or crisis communications will be involved (and  create your crisis management SOPs separately too!), and what the service level agreements are for each  group.

From here, you can apply the considerations laid out above to truly customize your program and ensure  compliance. This is a significant amount of work, so if you are interested in learning how to utilize this  information to build a successful and compliant community management program, please reach out to your  CMI/Compas lead.