By Leanne Drown
You may have heard about Dr. Alexandra Thran, who was fired from Westerly Hospital last year for posting information on Facebook about a trauma patient she’d seen that day. Thran’s posting did not include the patient’s name, but she wrote enough that others in the community could identify the patient. Dr. Thran was reprimanded by state regulators, ordered to pay a $500 administrative fee and must attend a continuing education course.
Dr. Thran’s story is one of many like it, and something that could happen to one of your doctors if they’re unaware of the rules & regulations for interacting with social media. While the FDA has yet to release official guidelines on social media, a simple social media policy can help to protect your employees and your practice in the meantime. If your medical practice doesn’t yet have a social media policy for your employees, it’s time to think hard about this example and get writing. Here are the 9 most important parts of an easily-understood, clear social media policy for your practice:
- Introduction: Let your employees know why you have decided to write this policy and encourage them to engage on social media as long as they follow the guidelines.
- HIPPA: Above all, patient information must remain private. Instruct your employees not to share ANY patient information without written permission from the patient.
- Conduct: Remind employees to be respectful and professional to fellow employees and adhere to your employee code of conduct.
- Questions: Clearly state who can be contacted with any questions, and remind your employees that “if they have a question about whether or not they should post something, the answer is no.”
Personal social media use
- Friending patients: Be clear as to whether or not your employees are allowed to become friends with patients of your practice on their personal social media pages. It is generally recommended that patients not befriend (or accept requests from) current patients.
- Disclosure: Instruct your employees to clearly disclose their relationship to your company if communicating publicly about your company.
- Disclaimer: Instruct your employees to use a disclaimer if they publish a blog, post a comment, or share an image that has something to do with your company. e.g. “The postings on this site are my own and don’t represent the positions, strategies or opinions of my employer.”
Company social media use
- Posting on behalf of your practice: Be clear about whether or not employees are allowed to post on your company blog, Facebook page, Twitter account, etc on behalf of your practice. If you decide to allow them to post, create clear guidelines for content.
- Interacting with your practice: Make sure to include a section about how employees are allowed to engage with your practice on its social media sites. Tell them if they’re allowed to post photos on your page, tag your company page in their posts, etc.