Developing a Social Media Policy that Mitigates Risk, Enhances Communication
By Debra Wood, RN, contributor
May 23, 2012 - “Can we tweet about this?” “Should our chief medical officer respond to a Facebook post about that?” “Is there anything in our new services video that should be removed before posting on YouTube?” As more and more healthcare providers are using social media tools to communicate with patients and others in the online community, the questions about what to say and what not to say continue to grow. A social media policy can provide the answers and help avoid potential risks while enhancing the organization’s ability to engage its audience effectively.
Jordan Battani called social media a huge opportunity for healthcare organizations to engage patients in their own care.
“The opportunity that social media tools and networking represent for engaging with consumers is enormous,” said Jordan Battani, managing director of CSC’s Global Institute for Emerging Healthcare Practices, headquartered in Falls Church, Va. “These are different kinds of communication tools than healthcare has worked with before, and as an industry or sector, we have strong professional and legal requirements around privacy and confidentiality. Maintaining those standards is challenging in the open communication world of social media.”
And it’s not just an issue for large health systems; all healthcare providers, including physician practices, need to recognize their responsibilities and take steps to protect themselves.
“As the lines between personal and professional become blurred through social media and the ubiquitous use of mobile devices for always-on communicating, it’s imperative that the medical community know how to participate in and keep up with social media,” said Mark Britton, founder and CEO of Avvo.com, a social media platform based in Seattle, which provides a health and legal question-and-answer forum and directory of physician and lawyer profiles.
The case for a policy
A social media policy sets the standards for engaging with constituencies and for protecting their privacy. At minimum, the CSC’s Global Institute for Emerging Healthcare Practices recommends, “the policy should reiterate that employees must adhere to legal requirements, federal regulations, and corporate policies and procedures in their social media use.”
“The goal for any social media policy should be to mitigate the risk of HIPAA (Health Insurance Portability and Accountability Act) violations and help physicians establish an online presence to create good ambassadors--regardless if their objective is to attract new patients, expand their referral network or simply to manage their online reputation,” Britton added.
Cleveland Clinic developed its social media policy three years ago.
“We recognized the need to provide a set of standards for our activity in this area that would provide a framework for our audience and our employees to have an open and productive dialogue,” said Joe Milicia, senior public relations manager at Cleveland Clinic in Ohio. “Our organization is committed to putting patients first, and our social media policy provides a set of expectations for social media users that allow us to maintain that environment.”
Milicia noted that Cleveland Clinic has 50,000 followers on Twitter and more than 77,000 on Facebook with high engagement scores.
“We have a high level of interaction with our audience,” he said. “Our social media policies have provided the foundation for this open environment.”
Developing a policy
Representatives from the legal and human resources departments, compliance officers and other staff members should participate in a hospital or health system’s policy development.
Battani pointed out that a social media policy has a number of clinical implications, and is not simply a function of the marketing department. In addition to staff, she also recommended including patients in the development of the policy, so the organization can learn what they prefer.
Policies should specify what information can and cannot be published on social media sites, according to CSC’s guidelines. They also should encourage individuals to keep the content of postings professional and respectful of colleagues and patients.
“As a healthcare professional, you can never take off your privacy, security and confidentiality hat,” Battani said. “One of the features of an effective social media policy is the articulation of behavioral standards not just for participating in a work-related effort but when participating on a personal level.”
Michael Sacopulos said employees on social media should follow existing policies, write in the first person, disclose any connections to the practice, be respectful to those inside and outside the organization, and not allow social networking to interfere with work commitments.
Michael Sacopulos, an attorney in Terre Haute, Ind., said in addition to protecting patient privacy, employees should refrain from directly or indirectly publishing or airing commentary about a physician and his or her practice, expertise and/or treatment, and employees should use all reasonable efforts to prevent any member of their immediate family or acquaintance from engaging in any such activity. Blogging and networking activity should not interfere with work commitments. The policy also should apply to “business associates” as defined under HIPAA, he said.
“Social media has become omnipresent and these guidelines are to help physicians, practices and hospitals as they seek to embrace or are dragged into what is a very different world in which we communicate today,” Sacopulos said.
Linda Pophal said a key consideration when considering the development of social media policies is whether to develop a separate policy or to integrate social media issues into other existing policies.
Linda Pophal, CEO of Strategic Communications in Chippewa Falls, Wis., and author of The Essentials of Corporate Communications and Public Relations, recommended weighing whether to develop a separate policy addressing the use of social media or to integrate issues related to social media into other existing policies regarding who is authorized to speak on the company's behalf and prohibitions against sharing proprietary information.
“I like to approach the issue from a broader communication standpoint than simply social media,” Pophal said. “The issues are really the same, just broader, with the potential for more impact.”
Model social media policies exist and can be helpful in drafting a policy.
The Society for Healthcare Strategy and Market Development, affiliated with the American Hospital Association (AHA), advocates for the development of a social media policy and recommends researching existing healthcare approaches and reviewing policies of organizations outside of healthcare.
The Federation of State Medical Boards recently adopted new policy guidelines on the appropriate use of social media and social networking. Violations of online professionalism are prevalent among physicians, according to a recent study published in the Journal of the American Medical Association, which found 92 percent of state medical boards in the United States have received reports of violations of online professionalism.
The American Medical Association (AMA) released its policy in 2010. It talks about monitoring one’s own Internet presence, using privacy settings, maintaining boundaries, and separating personal and professional online content.
Putting a policy in place
Once the policy is established, the organization or practice should meet with staff and educate them about the policy and what’s expected and entertain questions to ensure everyone understands what it contains.
“There has to be real hands-on training, and there has to be follow-up,” Battani said.
In addition to understanding what is allowed or prohibited, Pophal said, employees must also understand why.
“This information must be conveyed on a regular basis, not just upon hire and not just once a year during annual in-services,” Pophal said.
For the public, healthcare providers should post disclaimers, CSC suggests, ensuring people do not think information from a social media site is medical advice or the position of the organization. It also behooves healthcare providers to post that readers should call 911 in an emergency rather than posting questions on a social media site.
Although people hold opposing views about how to handle negative posts, CSC recommends stating that the organization or practice reserves the right to oversee and monitor user activity and those offensive comments be removed. Trying to address a problem online could escalate the issue.
“Logically, you want to defuse the rancor,” Battani said. “The bigger, potent threat is if there is a real quality of care or quality of service complaint or a patient safety issue. The last place you want people to identify it is through social media, because it could get lost in the shuffle.”
Healthcare organizations must develop an effective method of monitoring social media, identifying problems and resolving them.
“These communication tools represent huge opportunity at a time when healthcare organizations and professionals need more effective and efficient ways of communicating with one another and their patients,” Battani said. “But it’s not trivial to implement them, and you cannot just ignore it.”
© 2012. AMN Healthcare, Inc. All Rights Reserved.
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