They're sighing because Facebook just announced another update to its page layout. My colleague Samantha Arabolu has the full rundown here: http://ow.ly/uIh6l
The changes themselves are not earth shattering, and in reviewing them with Sam, I didn't see anything that would cause me to think an initiative that was perfectly fine before would suddenly become non-compliant in after the change.
[BTW, if you disagree and think some of these changes seriously jeopardize things, please say so in the comments on this post.]
Nonetheless, the sigh was heard because all of those materials will have to be updated in light of the new layout, and as FDA made clear at the DIA Marketing Pharmaceuticals conference last month, when the third-party platform you're engaging in updates, then you have to re-submit your materials under Form 2253.
A: (Abrams) Yes, you do. Could completely change presentation of the piece #diamktg— Dale Cooke (@PhillyCooke) February 27, 2014
And here's the one and only thing I can guarantee you about Facebook: this is going to happen again. The only guarantee in such arenas is change. And most of those changes will probably be similar to this one. They'll require you to adjust materials, re-review them with MLR, and resubmit to FDA under Form 2253; but they're not likely to revolutionize the platform in a way that significantly alters the core functionality.
So, when you decide to engage in third-party platforms, you simply have to factor in the cost associated with these types of updates because they will happen, and when they do, there will be a cost to update your promotional materials.