Questions to ask when creating a social media policy in healthcare

Social media has transformed how we communicate and poses unique challenges for healthcare providers and organizations. Examples of recent real-world social media violations include employees sharing patient information (e.g., Ballad Health in 2022), gossiping about patients (e.g., Glenview Nursing Home in 2019), and inappropriate employee conduct (e.g., Citadel Winston-Salem in 2021).

By understanding HIPAA regulations, implementing clear social media policies, and educating employees, healthcare organizations can navigate the world of social media while maintaining patient privacy and HIPAA compliance. A comprehensive social media policy would require organizations to obtain patient authorization, use secure communication methods, and guarantee third-party security with signed business associate agreements (BAAs).

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HIPAA, healthcare, and social media

Social media platforms allow healthcare providers to interact directly with their audience. With social media apps and posts, healthcare organizations can provide a dynamic and accessible channel for reaching diverse audiences. Social media offers such benefits to healthcare organizations that encourage patient education, community engagement, and professional networking.

In fact, content on social media can extend beyond traditional healthcare topics to address broader health and wellness concerns. Healthcare organizations can position themselves as valuable sources of knowledge by sharing general health information and preventive tips and highlighting national health observances. However, healthcare providers must be careful about how they use social media to avoid violating HIPAA by exposing a patient's PHI.

HIPAA regulations uphold patients’ rights and ensure the security of sensitive data, reinforcing the integrity of healthcare practices. While HIPAA doesn't explicitly mention social media, its principles about communication and security extend to digital platforms. Healthcare providers and organizations must be cautious about how they handle patient information on social media to avoid violating HIPAA regulations.

There are limitations to its use, and employees should understand what they can—and cannot—say on social media through a social media policy.

What is a healthcare social media policy?

A social media policy provides guidelines on the technology’s use, setting expectations and listing best practices. Ensuring patient trust and privacy is integral to a HIPAA compliant social media policy. The use of a well-thought policy increases confidentiality, brand reputation, security, and compliance.

Developing protocols to address social media use will not only make maintaining HIPAA compliance easier but also increase its efficiency. When considering a social media policy, a healthcare organization must include how it plans to safeguard patients’ information through confidentiality, encryption, access controls, and adherence to the minimum necessary standard.

Elements of a social media policy should incorporate communication procedures, tools and techniques, and defined roles and responsibilities of staff. It should also include specific HIPAA compliance security strategies that block a data breach and lay out a plan in case one does occur.

A well-thought-out strategy ensures clear and consistent communication to support proper patient care. Strong measures help healthcare organizations maintain all health-related information, ensuring patient data always remains secure. Finally, upholding confidentiality builds trust and strengthens the patient-provider relationship.

Risks of not using a social media policy in healthcare

In the first half of 2018 alone, more than 56% of the 4.5 billion compromised data records were attributed to social media incidents. As shown above, this trend continues today. Not using a social media policy in healthcare can lead to uncompliant behavior, improper communication, and PHI being accessed by cyberattackers.

Common mistakes in communication include using unencrypted channels, failure to obtain patient consent, not training staff adequately, and neglecting to update tools and procedures. Poor, unprotected communication can result in misdiagnoses and other medical errors that can lead to avoidable health complications and adverse incidents for patients. HIPAA violations can also lead to reputational damage, legal consequences, and financial penalties.

Healthcare organizations can reduce such issues and risks and maintain HIPAA compliance by implementing secure communication practices. HIPAA compliance demonstrates an organization's dedication to safeguarding patient privacy and adhering to healthcare regulations.

Questions to ask when creating a social media policy in healthcare

An organization’s social media policy depends on its needs and will change from organization to organization and situation to situation. Healthcare organizations should ask themselves the following questions, among others, about the elements and strategies to include in a social media policy.

Why do you want to use social media?

Does another company need to implement any of your social media strategies?

How should patient consent be gathered, given, and shared among different social media apps?

What is the minimum amount of information to be revealed on social media?

What costs are involved with social media use?

What security measures should be used for what social media channels?

How do you plan to monitor, evaluate, and audit your strategy?

How and when do you plan to update your strategy?

What happens in the event of a breach?

How do you plan to train employees on social media best practices?

Healthcare professionals and organizations can easily use social media when a social media policy is in place. With it, healthcare organizations can protect patient privacy, comply with HIPAA regulations, and promote better health outcomes through clear and secure communication.

Think about: Is posting on social media a HIPAA violation?

What does a HIPAA compliant social media business associate look like?

A HIPAA compliant social media business associate:

• Will sign a BAA and mention HIPAA compliance
• Understand and can answer questions about HIPAA
• Have HIPAA-related policies and procedures available
• Provide reviews, testimonials, and case studies from other healthcare organizations
• Utilize security measures that comply with the Security Rule’s technical, physical, and administrative safeguards
• Deliver staff training on HIPAA and PHI security
• Show that they continuously update their security based on new laws and new issues

Through constant monitoring with strong plans and strategies as a backbone, healthcare organizations can ensure they remain HIPAA compliant and protect patient information while providing strong patient care.

FAQs

Can healthcare providers connect with patients on social media?

Connecting with patients on social media is acceptable but requires careful consideration. While HIPAA doesn't directly mention social media, its principles extend to online engagement. Ensure your interactions steer clear of sharing any private health information. Prioritize patient privacy by following this guideline, thereby aligning with HIPAA regulations.

Can healthcare organizations address patient queries on social media platforms?

Healthcare organizations should refrain from discussing specific patient health details on social media. Encourage patients to use secure communication channels or contact their healthcare provider directly for personalized inquiries.

How can social media be used for HIPAA compliant patient engagement?

Use social media for sharing general health info and educational content. Encourage patients to seek personalized advice through secure channels to ensure privacy.

Can healthcare services be advertised on social media?

Yes, advertising healthcare services on social media is allowed, with adherence to privacy guidelines. Ensure that advertisements avoid revealing patient-specific information to maintain a balance between promotion and privacy in compliance with HIPAA.

Read more: Leveraging social media platforms for HIPAA compliant patient outreach

What if a staff member accidentally posts PHI on social media?

In the case of accidental PHI disclosure on social media, take immediate action. Report the incident promptly and follow the corrective steps outlined in your organization's HIPAA compliance policy. This may involve notifying affected patients and relevant authorities to mitigate potential risks.

Related: How to respond to a data breach