Every Physician Practice Should Have a Social Media Policy

The best thing you can do to ensure you’re protecting your practice from the perils of social media, while still maximizing its potential, is to designate a social media policy.

  •  Clearly defined how you plan to use social media sites for marketing your practice, and be sure your employees understand what they may post on social media websites from their personal accounts.
  •  Patient privacy and confidentiality must be protected at all times, especially on social media and social networking websites.
  •  Prohibit providers and employees from posting any identifiable patient information online.
  •  When using the Internet for social networking, employees and providers should use privacy settings to safeguard patient information to the highest extent possible. They should also realize that privacy settings are not absolute and that when information exists online, it will likely be there a long time (if not permanently).
  •  Restrict “friending” of any practice patient or family member. This allows the provider or employee to politely decline the request, stating that it would be against practice policy.
  •  Have patients authorize the use of their personal information online, including for use in testimonials, success stories, photos, videos, etc. If a practice want to use pictures or videos for promotions or other reasons, make sure the patients sign a valid HIPAA authorization form. These forms are required before a patient’s image can be used in any medium for educational, promotional, advertising, or other purposes.
  •  HIPAA requires that patients sign a valid authorization form declaring their permission, before a Practice can market to that patient. This authorization form must be kept by the Practice for six years.
  • Ensure that vendors who assist you in social media activities sign a business associate agreement. Practices must sign business associate agreements with these vendors that obligate the vendor to safeguard the patient information it maintains or has access to.
  • Train providers to apply the same ethical and professional conduct online that they use in their daily actions offline. The American Medical Association published a policy to guide providers in the use of social media, entitled “Professionalism in the Use of Social Media.” Recommendations include:

° Providers who interact with patients on the Internet must maintain appropriate boundaries of the patient-physician relationship in accordance with professional ethical guidelines, just as they would in any other context;
° Providers should consider separating personal and professional content online;
° Providers should recognize that actions online and content posted can negatively affect their reputations among patients and colleagues, and may have consequences for their medical careers.

About the Author: Marcia L. Brauchler, MPH, CMPE, CPC, CPC-H, CPC-I, CPHQ, is the President and Founder of Physicians’ Ally, Inc., a full service healthcare company. Since 2000, Marcia and her uniquely qualified employees and consultants have provided advice and counsel to hundreds of physicians and practice administrators, resulting in improved and enhanced efficiencies in their business operations. Marcia and her team provide education and assistance on how best to negotiate managed care contracts, increase reimbursements to the practice, and stay in compliance with healthcare laws. Services also include professional credentialing, coding, and coding certification education. Healthcare providers and practices can also purchase from the company the Physicians’ Ally HIPAA Policies and Procedures Manual and its general Compliance Manual by visiting the company’s website at www.physicians-ally.com.

John Verhovshek
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John Verhovshek, MA, CPC, is a contributing editor at AAPC. He has been covering medical coding and billing, healthcare policy, and the business of medicine since 1999. He is an alumnus of York College of Pennsylvania and Clemson University.

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