The following is based on a presentation at the Rhode Island chapter of AHIMA’s winter meeting held January 20, 2017 in Warwick, Rhode Island.
by Lisa Eramo, MA
Angela Carr, JD, partner at Barton Gilman, gave a very interesting presentation about the impact of social media on healthcare privacy and security. In particular, she said hospitals increasing rely on social media for the following purposes:
1. Attract and engage patients
2. Improve Google hits
3. Recruit patients for clinical trials
4. Attract employees
However, she urged organizations to think about the implications of social media on patient privacy, adding that an internal social media policy for employees is paramount. Such a policy should include the following components, she said:
1. Definition of social media (including websites that fall under this category)
2. Who can access social media, and why
3. Fines for violating HIPAA
4. Examples of what is considered a HIPAA breach
5. Specific consequences for non-compliance
6. Contact information of someone who can answer questions about the policy and its application
Note: Massachusetts General Hospital provides an employee social media policy that you can view here. Carr cited this policy as an example to which other organizations can refer when developing their own guidelines.
Provide an in-service to explain the policy, and apply it consistently to all employees, she added. Remind employees that even the most well-intentioned individuals can inadvertently breach confidential patient information. She provided this example: An employee takes a picture of herself eating birthday cake at her desk and posts it on Facebook. The employee doesn’t realize that five patient records are visible on her desk. This ‘background information’ is what many people fail to think about, she says.
She also urged organizations to create a social media policy for external users. This policy basically sets the ground rules for interacting with the organization’s social media sites. It should include clear terms of participation, the purpose of the organization’s social media presence, the prohibition of abusive terms, and more. Click here to view an example of Massachusetts General Hospital’s social media guidelines for individuals who wish to interact with the hospital through social media.
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