HIPAA, the FDA, and Patient Engagement: A Social Media Survival Guide
Increasingly, healthcare providers, large and small, recognize the potential benefits that social media offers as a channel for patient engagement, but struggle to establish effective, HIPAA-compliant social media programs. The desire is there—which is why 200 people representing 20 states and five countries converged on Rochester, Minnesota to take part in a Social Media Summit just last month. Why Rochester? Because it is home to a recognized leader in healthcare social media: the Mayo Clinic.
While more than half of the hospitals in the US have regulations against employee use of social media at work, the Mayo Clinic has taken a different approach: the organization actively encourages employees to engage in online healthcare conversations and already has a decade of experience of social media management.
“The key is to train health care professionals to do this effectively, strategically and compassionately,” said Dr. Farris Timimi, medical director of Mayo Clinic Center for Social Media. What are some of the best practices used by the Mayo Clinic and other healthcare social media trailblazers?
Craft a Strategy for a Regulated Landscape
Admittedly, the healthcare industry faces unique regulatory challenges. Rather than getting hung up on the ‘what-ifs’ and failing to move forward, healthcare organizations need to approach compliance risks with a well-honed strategy.
- Set an employee use policy for social media and provide staff training. This should clearly outline the standards for acceptable – and unacceptable – posts with real-world examples.
- Implement monitoring tools that provide real-time alerts to catch potential problems before posts go live.
- Maintain an auditable trail of digital communications to satisfy any regulatory record-keeping requirements.
Whether you’re a healthcare provider, insurer, manufacturer or pharmaceutical company, you must comply with a host of state and federal policies, particularly HIPAA protections for private patient information and FDA limits to promotional messaging about products and services.
HIPAA limitations are fairly straight-forward: no information that can be used to identify a patient. Social media is a two-way communication, however, so healthcare organizations must also evaluate patients’ posts to ensure privacy issues do not arise.
The FDA limits, which apply more to bio-tech or pharmaceutical companies, require that benefits and risks be treated equally—not easy when you’re working with the 140-character limit of Twitter. The latest guidance from the FDA does allow for providing a link to the benefit-risk information in deference to limited space. The FDA also requires providers to rigorously address misinformation originating from third-parties, and consumers’ reports of negative experiences could count as adverse events.
It may sound complicated, but Dr. Timimi has a more succinct way of saying it: “Don’t lie, don’t pry, don’t cheat, you can’t delete.”
Match Your Social Media Strategy to the Patient Journey
Hootsuite, a leading social relationship platform, has put together a toolkit to help healthcare providers navigate the social media landscape. In addition to addressing the compliance and employee training aspects of social media strategies, Hootsuite suggests that healthcare providers must develop practices that align with the patient journey:
- Pre-symptomatic. This is where you can drive awareness and establish your organization as a partner in health for the community at large with educational social media campaigns. As you build credibility, you also strengthen your brand and ability to attract patients.
- Symptomatic. According to Pew research, 77 percent of adults who look for health information online report that they use search engines to diagnose symptoms—their own or others. Optimizing your educational content to be found on search engines improves visibility when patients begin their search.
- Diagnosis. Once patients receive a diagnosis, their research online continues, with a narrower focus. This is the ideal time to engage patients who are looking for on-going care with content marketing that “owns search keywords related to conditions and treatments.”
- Treatment. At this stage, in addition to seeking information about their diagnoses, patients often look for emotional support on social media. Understanding where your patients are looking for help—or even asking for it—can even improve outcomes. Nurses with the U.S. Navy-Marine Corps Relief Society, for example, have successfully identified suicide risks and intervened thanks to social media engagement with patients.
- Rehab and Recovery. By staying engaged with patients post-treatment, hospitals can increase patient satisfaction—which Hootsuite points out can “drive referrals and secure satisfaction-dependent funding.”
Studies of Internet use by the Pew Research Center reveal that 59 percent of adults turn to search engines and social media throughout the patient journey—from Googling symptoms or reading online reviews for providers before making a doctor’s appointment to watching videos and connecting on forums for patients with shared diagnoses. The 2015 c2b Consumer Diagnostic found that a quarter of adults age 18+ have actively used social media to share opinions on hospitals and physician practices.
Hospitals that connect with patients, wherever they’re looking for information, are better positioned to not only improve patient engagement, but to realize positive returns on engagement in the guise of greater brand awareness and empowered patients who are more proactive about managing their own health.