MDS Alert

Many of the active criminal cases involving charges against former SNF employees involved posting photos or videos of residents on social media. Establish your facility’s social media protocols, and keep your policies current, especially with new smartphone applications being developed and released every day. Involve staff when deciding on social media policies and protocols.

Follow these tips, courtesy of the American Health Care Association and the National Center for Assisted Living:

• Establish privacy requirements for your particular facility and make sure all staff are aware of exactly what requirements they should follow.
• Require staff to acquire written authorization from residents before taking photos or using their images on company-sanctioned social media.
• Prohibit staff from taking photos of residents for personal use.
• Make your rules about social media use explicit in your facility’s policies, and include specific examples.
• List and enforce consequences for staff who fail to follow these policies.
• Make sure that all staff know they are responsible for protecting residents, including their dignity, and that any breach in facility social media policy should be reported to management.
• Dedicate specific staff to managing your facility’s social media presence, and make certain that facility account settings (passwords, contact information) are secure, especially in the event of staff turnover.
• Incorporate these policies into regular and ongoing staff training.

Utilize these tips as well:

• Any personal social media activity should occur on a private account and not the facility’s social media accounts (if applicable).
• Don’t use the facility’s logo or anything trademarked on personal social media accounts.
• Deleted or disappearing photos or videos can be recalled. A few of the active criminal cases involving former SNF employees allege that the employees shared photos over Snapchat, a social media app where photos “disappear” — except that they don’t.
• There are new federal regulations that levy F-tags and fines against a facility if an employee harms the resident through taking and sharing of photos or videos or dehumanization.
• Remove or cover all personal information if taking photos of a party or gathering for social media or sharing.

For more information, see: www.ahcancal.org/News/Documents/SocialMediaBestPractices.pdf.