Establishing HIPAA adherence for healthcare teams using social media platforms.

It would be difficult to come across healthcare marketers who are unaware of the importance of social media for healthcare, as stated by Jill Florence, the Director of Enterprise Sales at Sprout Social.

Florence emphasizes that social media is an essential aspect of increasing brand recognition and establishing relationships with patients, doctors, and members of the community. However, marketing teams that operate in the digital space may find it difficult to address the apprehensions of security and privacy teams, particularly when it comes to navigating the intersection between HIPAA regulations and social media platforms.

Numerous organizations find that adhering to HIPAA compliance measures hampers their strategic efforts, due to the fact that the most captivating healthcare content they produce involves cutting-edge research, patient stories, and significant medical advancements, all of which necessitate extensive approval procedures and meticulous implementation. In this manual, we will explain the essentials of maintaining HIPAA compliance on social media platforms and highlight healthcare companies that excel in social media engagement while adhering to regulatory constraints.

Kindly be aware that the content of this article is not meant to serve as official legal counsel. It is advised to read our complete disclaimer prior to proceeding with the article.

The effect of HIPAA on the content you post on social media platforms.

HIPAA privacy laws protect sensitive patient information from being disclosed publicly, including on social media. The HIPAA Privacy Rule expressly protects patient health information as it relates to how the data is shared, including in marketing and advertising efforts.

Sensitive protected health information (PHI) includes data about a patient’s past, present or future medical conditions, provision of healthcare to the individual and past, present or future healthcare payments. Given social media platforms gather user information, track behavior and have license to use your visual assets, it’s easy to see why these regulations exist.

Healthcare providers must be vigilant when creating content for social media in an era where patient photos and reviews are commonly shared. It is essential to adhere to HIPAA regulations and ensure that patient health information is not shared or disclosed on social media platforms. Non-compliance with these rules can result in significant financial penalties and damage to the company’s image.

However, as Katherine Van Allen, Senior Solutions Engineer at Sprout, points out, the benefits of social outweigh the risks. “Social media should be part of healthcare organizations’ strategy. The people you need to reach are on social—whether it’s prospective patients or employees. Without a social presence, you aren’t a part of vital conversations happening about your system. From discourse about a team member or location, clerical mistakes and legal actions, or rapidly spreading misinformation about a disease or treatment plan. Tuning into social media listening will help you pinpoint key areas of opportunity.”

Guidelines for creating a brand that adheres to HIPAA regulations and social media best practices.

Though you should always consult your legal counsel and compliance team regarding HIPAA compliance on social media, here are general best practices to follow as you create your brand guidelines.

Craft policies and train your team

Start by consulting with your legal and compliance teams, and make them a key partner in validating the legality of your strategy, campaigns and content. Work with them to develop a social media compliance protocol, which should include instructions for corresponding with people via social media.

Educate your team on this procedure by collaborating to develop HIPAA compliance training that includes social media instruction. Emphasize the correct handling of customer information on social media and typical HIPAA infractions in your training.

Follow de-identification best practices

When crafting new social media content, remove all PHI from your posts. PHI includes health information used alongside the following identifiers:

• Names (first, middle and last)
• Geographical indicators smaller than a state
• All elements of a date (except year)
• Phone and fax numbers
• Email addresses
• Social security numbers
• Medical record, health plan beneficiary and account numbers
• Certificate or license numbers
• Vehicle identifiers
• Device attributes
• URLs and IP addresses associated with patients
• Biometric identifiers
• Photographs of full faces and other unique physical identifiers
• Any other numbers or codes that could identify an individual

For more context, while a patient’s name paired with their vital signs is considered PHI, their vital signs alone are not.

Keep an eye out for any breaches of HIPAA regulations.

Even if you take every precaution to limit the use of PHI in your content, patients can still put your compliance at risk by sharing personal information themselves. Prevent this by adding disclaimers to your direct message interactions and brand profiles. Ask patients to refrain from sharing any PHI and inform them where they should route inquiries.

If a patient should mention or DM you and compromise PHI, delete the message immediately, and route them to a more appropriate channel. Florence advises, “Even if you add a disclaimer to your profile or DMs, some patients will still seek out medical advice. To combat this, some organizations use chatbots and triaging tools to automatically alert them of potential PHI, and respond to or delete sensitive content.”

Utilize a feature such as Sprout Social’s Saved Replies to promptly address customer inquiries with pre-crafted responses and guide the conversation towards a protected channel. Additionally, Sprout’s chatbot creator can be employed to seamlessly transfer social media users to an email address or alternative secure channel for discussions pertaining to healthcare.

With Sprout’s Smart Inbox, you can use tagging and filtering to flag messages that contain PHI, and build workflows that delete those messages.

Build a process for patient approvals

In certain situations, patients (or their relatives) may want to share their experiences with your viewers, such as this charming Halloween TikTok from the Cleveland Clinic’s NICU.

Have a streamlined and clearly documented process in place for gaining written consent and HIPAA authorization to disclose PHI from a patient before sharing those stories, photographs and/or videos.

Keep informed about updates to laws and regulations

Make it a regular practice to stay up to date on legislative changes at the federal and state levels. Regularly review resources like the U.S. Department of Health and Human Services (HHS) website. You can also follow the HHS and National Law Review on social for real-time updates, including case rulings regarding HIPAA data breaches.

Looking for more resources? We put together a HIPAA compliance on social cheat sheet that can help you remain compliant, while executing an effective and creative social strategy.

Frequent violations of HIPAA regulations and the influence of social media.

While HIPAA compliance on social is complex, the monetary, reputational and, most importantly, patient well-being risks are too steep to get it wrong. Here are the most common HIPAA violations you should avoid.

Hiding patient details in plain sight

Even if you don’t explicitly include faces, names, dates or other obvious identifiers, some situational details can reveal a patient’s personal information. Both Florence and Van Allen advise close review of photography and videos before posting. Ensure there is no protected information in the background of your media.

Van Allen cautions, “An image that appears harmless, like a picture of a staff room, could lead to a breach. A person could enlarge the photo and potentially see a patient’s chart on the table, revealing their name or other Protected Health Information.”

Validating health information

“A lot of patients message healthcare brands thinking their message will reach their doctors—which means they include sensitive PHI in their outreach,” Florence says. As we mentioned in the previous section, it’s critical to delete any PHI, even when the patient provides it unprompted.

Many organizations overlook an important detail: it’s also necessary to avoid confirming any Protected Health Information (PHI). For instance, if a patient mentions their medical condition on your post, you should not recognize that condition in your reply, as it may breach HIPAA regulations. Here are some illustrative situations:

Example patient message: @Hospital, I have recently been diagnosed with diabetes, and I was wondering which of your doctors specializes in diabetes care?

Not HIPAA compliant: @Patient, we know navigating a new diabetes diagnosis can be challenging, and we’re here to help. Call Dr. Smith’s office directly to schedule a consultation.

HIPAA compliant: @Patient, we have deleted your comment to protect your privacy. Please call or reach out to our team via email for help.

Limiting training to corporate channels and paid personnel

By limiting training to corporate channels and paid personnel, healthcare organizations create knowledge gaps that can cause major fall-out. For example, an excited intern could post a selfie with a patient. Or a residency student could accidentally reveal PHI in a funny TikTok.

Healthcare organizations should remember that HIPAA applies to everyone under the control of a covered entity—including volunteers, students and unpaid personnel. It also encapsulates social profiles beyond the corporate account, including the personal accounts of staff members.

The implications of HIPAA for your social media service providers.

HIPAA compliance and security should be top of mind when selecting software vendors and tools. During your platform evaluations, expect your security and privacy teams to be vigilant about the ways data is used when it’s integrated into larger tech stacks.

Find a management solution with permission levels and message approval functionality to ensure only responsible parties can post. Ensure that cybersecurity measures are in place to protect PHI on electronic devices such as encryption or firewalls.

Go beyond the basics and seek out a social media management tool that agrees to sign a business associate agreement (BAA)—a legally enforceable document outlining the duties of each party in relation to PHI and HIPAA adherence. As Florence explains, “Partner with a company like Sprout Social that is prepared to sign a BAA and share the risks and obligations with you.”

Healthcare brands to learn from

These four healthcare organizations demonstrate that having an active social media presence is still possible and important, even in regulated industries.

Mayo Clinic

The Mayo Clinic, which is recognized as the best hospital in the country, utilizes social media platforms to enhance their reputation as an employer. An example of this is when they reposted content from the head of their transplant department, who was commemorating a month of successful operations. It’s important to note that the post did not disclose any confidential patient details, but rather highlighted the achievements and exceptional quality of the transplant staff.

Mayo Clinic also shares profiles of their volunteers, physicians and other personnel to further humanize their company, like this heartwarming video about a Holocaust survivor-turned-volunteer.

The hospital system enhances their posts by adding general health and lifestyle advice to motivate their followers and encourage overall wellness, such as in this series of images showcasing the advantages of daily physical activity.

Cleveland Clinic

Cleveland Clinic, a renowned academic medical institution, keeps up with current healthcare discussions and utilizes their knowledge to update their community on recent public health findings.

Like in this Reel where they investigate the benefits of the latest social media health craze, cold plunging or cold showering. The post breaks down how to reap the rewards of the trend, while staying safe and healthy.

The medical center also shares top-of-mind public health reports produced by their organization. They typically briefly summarize the key findings of the report, while including the link so people can read more, like they did in this post.

Boston Children’s Hospital

Boston Children’s Hospital houses the world’s biggest pediatric research program within a hospital setting. The institution leverages its social media platforms to showcase innovative research and the scientists responsible for it, as demonstrated in this post featuring a leading clinical geneticist who is improving health outcomes for children.

They also feature the patients who benefit from their state-of-the-art treatments by interviewing their families, like in this feature on Facebook about the power of genetic testing for children with epilepsy.

Anthem Blue Cross Blue Shield

Anthem Blue Cross Blue Shield is a trusted health insurance plan provider. On social, they share meaningful statistics about the value they offer their members, including this post about the return on investment employers gain from investing in workplace addiction recovery and support.

They also showcase their recognition and certifications that highlight their dedication to providing quality care for members, such as this update about their acknowledgment by NCQA.

As a popular insurance plan provider, they receive a lot of inquiries about member policy details on social. Their care team illustrates how to route conversations from public forums to more appropriate, secure private channels, like in this reply where they ask a member to email their help center.

Navigate HIPAA and social media with confidence

Maintaining HIPAA compliance on social media requires a continuous, multi-faceted approach that includes working closely with your legal and security departments and providing education across different departments. Adhering to essential best practices that safeguard patient information and your organization’s reputation will enable you to confidently manage intricate HIPAA guidelines and build your social media presence.

Next steps: Now that you’ve read this article, put a meeting with your legal and security teams on the calendar to start planning your org-wide education efforts, and brush up on healthcare social media benchmarks to better understand social’s role in your community engagement toolkit.

Disclaimer

The information provided in this article does not, and is not intended to, constitute formal legal advice; all information, content, points and materials are for general informational purposes. Information on this website may not constitute the most up-to-date legal or other information. Incorporation of any guidelines provided in this article does not guarantee that your legal risk is reduced. Readers of this article should contact their legal team or attorney to obtain advice with respect to any particular legal matter and should refrain from acting on the basis of information on this article without first seeking independent legal advice. Use of, and access to, this article or any of the links or resources contained within the site do not create an attorney-client relationship between the reader, user or browser and any contributors or contributing law firms. The views expressed by any contributors to this article are their own and do not reflect the views of Sprout Social. All liability with respect to actions taken or not taken based on the contents of this article are hereby expressly disclaimed.

The post A healthcare team’s guide to HIPAA compliance on social media appeared first on Sprout Social.

The Health Insurance Portability and Accountability Act (HIPAA) is a federal law that protects the privacy of individuals’ health information. As technology advances, healthcare teams are increasingly using social media to communicate and collaborate with each other. However, this poses a challenge when it comes to HIPAA compliance. It is essential for healthcare teams to ensure that they are compliant with HIPAA when using social media.

The first step in implementing HIPAA compliance on social media is to create a policy that outlines the rules and regulations for using social media. This policy should include guidelines for posting, sharing, and storing information, as well as the consequences for violating the policy. It should also include information about how to handle requests for patient information and how to respond to inquiries from the public.

Healthcare teams should also be aware of the privacy settings on the social media platforms they are using. It is important to ensure that only authorized personnel have access to sensitive information. Additionally, healthcare teams should be aware of the data retention policies of the social media platform they are using, as this will determine how long data is stored and who has access to it.

When using social media, healthcare teams should also be aware of the risks associated with sharing patient information. This includes the risk of unauthorized access, as well as the risk of data breaches. Healthcare teams should take steps to protect patient information by encrypting data and limiting access to authorized personnel only.

Finally, healthcare teams should ensure that they are regularly monitoring their social media accounts for any potential violations of HIPAA. This includes monitoring for any posts that may contain protected health information or any posts that could be considered a breach of patient confidentiality. Healthcare teams should also be aware of any changes in the law that could affect their use of social media and adjust their policies accordingly.

Implementing HIPAA compliance on social media can be a challenge for healthcare teams, but it is essential for protecting patient information and ensuring that healthcare teams remain compliant with the law. By creating a policy, understanding the privacy settings, monitoring for potential violations, and staying up-to-date on changes in the law, healthcare teams can ensure that they are using social media in a compliant manner.

Source: sproutsocial.com