In recent weeks, Meta began to notify stakeholders about coming policy changes that could alter how health advertisers utilize its platforms. While no official guidance has been released, ADM has been gathering information from a number of sources so we can assemble a picture of what health marketers should expect in 2025.
What’s clear is that healthcare advertisers will need to pay close attention to these developments and start building contingency plans to safeguard themselves from any lost functionality that may result. In this blog, we’ll do our best to explain what we know so far, and what brands can do to set themselves up for success in 2025.
What’s Happening With Health and Wellness Advertising on Meta?
It appears imminent that Meta advertisers in certain sensitive industries, like healthcare and financial services, will lose some capabilities when advertising the platforms like Instagram and Facebook. What’s expected is that:
- Health and wellness brands seem likely to lose bottom-funnel event optimization: Advertisers in the space will certainly be among those subject to lower-funnel restrictions, which could prevent them from optimizing based on things like booked appointments and purchases to optimize campaigns. But while some sources seem to indicate a hardline stance, other communications from Meta reps seem to suggest that certain barebones lead forms could survive this policy change.
- Tracking capabilities will become limited: Conversion tracking and ad-specific attribution will face new restrictions, making it harder for health and wellness advertisers to evaluate the performance and impact of their campaigns.
- These changes will go into effect in January 2025.
As Marketing Brew pointed out in one of the best articles yet on this subject, the proposed changes do correspond with some officially-announced Meta policy. In November 2024, the social giant put out a statement reminding advertisers that it categorizes advertisers based on their data sources—websites and apps—and that it reserves the right to “restrict the sharing of specific mid and lower funnel events” based on those categorizations.
Categorization may go deeper than just industry type, however. According to ADM partner Freshpaint—a technology company that helps health advertisers safeguard mitigate data sharing violations—Meta will subcategorize companies within the “Health & Wellness” bucket into two groups: “Patient Portal” or “Provider.”
A health site or app that allows users to log in and access stored health information will likely fall into the “Patient Portal” group, which could face harsher restrictions than, say, a general informational website for a local health clinic. Freshpaint also speculates that condition-specific pages or brands with an eCommerce component of their health business may also be subject to escalating restrictions. If you’re interested in this topic, their write-up is highly recommended.
What Do These Changes Mean for Health Advertisers?
First and foremost, it’s important to note that these changes are being made to force advertisers towards adherence with existing laws—so savvy health advertisers should 1. Already be doing everything in their power to avoid potential compliance issues and 2. Be agile enough to shift strategies as policies change (which they often do).
Some things that brands should already be doing, as Freshpaint and ADM pointed out in a collaborative eBook on the health marketing compliance, include:
- Double-checking all their data collection and sharing implementations to ensure no PHI is being passed to Meta
- Using anonymized event names—think “Event #1” rather than “Appointment Booking”
- Removing Meta Pixels and replacing them with a Business Associates Agreement (BAA)-eligible technology like Freshpaint offers
In light of its new policy, Meta has indicated that advertisers should be prepared to “[shift] your focus to upper-funnel events to maintain effective audience targeting and campaign optimization.” Privately, some advertisers have been told to use other platforms to make their Meta campaigns more effective. In combination, those two points seem to indicate that Meta would probably prefer health and wellness brands treat its advertising suite as an awareness play and run their conversion-focused campaigns somewhere else.
Because these changes have yet to take effect or be formally and publicly explained by Meta, it’s difficult to say how exactly they will shake out. Health and wellness brands should:
- Keep an eye out for any direct communications from Meta regarding the status of their advertising
- Begin ideating new ways to utilize Meta as a top-of-funnel marketing tactic
- Plan for ways to replace potential lost conversions as a result of these changes
- Anticipate their site categorization and consider an appeal if they think they are wrongly categorized
- Continue following all health advertising compliance best practices on Meta and other platforms
Why Is Meta Changing Its Approach to Health Ads?
While Meta hasn’t voiced any specific reason for these changes, it seems obvious that it’s looking out for itself. In recent years, health advertisers have been smacked with heavy fines and penalties for failing to adhere to HIPAA’s restrictions on sharing protected health information (PHI).
Many types of identifying information (like IP addresses, email addresses, and names) can become PHI if they are combined with a health-related action—like signing up for therapy or purchasing a medical device or prescription. Advertisers who were tracking such conversions through Meta pixels were often unwittingly submitting PHI to Meta, thus violating the law.
Meta itself wasn’t the target of any of those recent FTC enforcement actions, even though they were found to have been committed using Meta’s technology. Previously, it and other advertising platforms have mostly taken a stance of “hey, don’t send us any data we’re not supposed to have.”
But without any direct enforcement, it was inevitable that many advertisers did—and many likely still are. Plus, even though it avoided any culpability in recent FTC enforcement, Meta has been named in data breach lawsuits regarding health information sharing in the past.
All in all, it was a situation that was bound to become untenable without some change on the platform’s behalf. By taking a clearer stance on health data sharing, Meta is likely trying to safeguard itself from receiving any data that could land it in trouble. In doing so, it may also be protecting advertisers who may not have understood that their actions were not compliant with various federal and state-level privacy laws.
A Meta spokesperson told Morning Brew that “these changes are part of our ongoing efforts to help ensure that we don’t receive information not allowed under our Meta Business Tool Terms.”
What Lies Ahead
Ever since a 2022 Markup investigation ignited new scrutiny on health-related digital marketing, there’s been a sense that platforms would eventually have to stop passing the compliance buck on to advertisers. Meta’s moves might be the indication that such a process is finally beginning.
Meta is not the only social advertising platform that’s shifting its approach to health and wellness ads. A little more than a month after being sued for tracking health user data, LinkedIn began notifying health advertisers that it was disabling the LinkedIn Insight Tag from any domains that may contain sensitive data.
More changes are sure to come on other platforms—and the industry is waiting to see whether other huge players, like Google, will take similar actions of their own. But it’s becoming increasingly clear that the ad platforms feel that they can no longer plead ignorance about the stakes of patient data safety.
As an experienced health marketing agency, ADM prides itself in prioritizing compliance for all of our clients in this space. We wouldn’t work with health brands if we didn’t believe in their mission or accept the challenge of navigating the complex, ever-evolving marketing environment they exist in. As policies change, our approaches will evolve, but our commitment to good marketing that doesn’t compromise patient data will always come first. If you’re interested in talking about how these changes might impact your marketing in 2025 and beyond, don’t hesitate to reach out to our team today.
