Practice Management Alert

Setting clear expectations is crucial.

Social networking is a huge part of today’s culture, and many practices are evaluating whether jumping on the bandwagon could help promote their services and bring in new patients. But if you don’t pay attention to the rules surrounding social media, you could get your practice in a sticky situation. 

Take a look at this expert advice to help your practice evaluate whether a practice Facebook page or Twitter feed might be a beneficial part of your marketing strategy. 

Explore Your Options

There are a variety of ways for your practice to be involved in the social media arena. Some of the most common include Facebook, Twitter, LinkedIn, Pinterest, and Tumblr. For medical practices, the first three are typical choices. 

“There are lots of choices in terms of if you want to communicate,” says attorney Wayne J. Miller, Esq., founding partner of the Compliance Law Group in Los Angeles in his recent audioconference titled “Social Network Marketing: Avoid Regulatory Pitfalls!”. “If you are a provider, you want to potentially communicate with ...  new patients or prior patients or ...  maybe even communicate with the colleagues or even others in a provider network ... social media ... makes a lot of sense for health care providers.”

Creating a social media presence for your practice allows you to communicate with existing patients, reach out to potential new patients, market your practice, promote your services, increase word-of-mouth referrals, and even become more involved in your local community, experts says. 

Example: In the fall, when flu season starts to settle in, your practice could post hand washing tips, flu shot hours, and local flu outbreak statistics our your practice Facebook page. You could also send tweets out on Twitter with daily provider tips on flu prevention or reasons to get vaccinated. 

Your practice can tailor the content you put out on social media to meet your needs. You can post practice updates, photos of your office, or preventive healthcare tips. Practices often find it helpful to include phone numbers, normal business hours, and provider profiles. How much you want to post online and where you want to post it is an individual practice decision. 

Review the Caveats

There are a few things to be careful of when your practice sets up a social media page or feed. 

First, Miller says that you need to be cautious about defining the doctor/patient relationship. “Be very clear about not creating a relationship with the patient if that’s not the intended in a social network setting; and most of the time it won’t be intended,” he warns. Your practice needs to be aware of the difference between general advice and taking over care for the patient. 

Next, be careful about licensing and scope of practice pitfalls. “One of the things that is of concern with the communications that involve a person in one part of the country and a doctor or a health care facility in another part is that often the states will say, ‘If you’re going to be providing [advice] to somebody in Wisconsin and you’re located in Florida, you need to be licensed in the state of Wisconsin in order to provide that advice,’” Miller explains. 

You’ll also need to be sure your online information does not violate HIPAA in anyway, including somehow disclosing patients’ protected health information (PHI). There are also questions of whether the social media networks that you connect with could be considered business associates (BA). 

Additionally: Be cautious about offering discounts via online networks or soliciting based on patient’s payment sources (i.e., the insurance they have), as you may be subject to anti-kickback, Stark, or solicitation laws. 

Differentiate Social Media and Telehealth Services

Creating a Facebook page, setting up a Twitter account, or posting videos on YouTube is meant to be a marketing and promotion strategy for medical practices. Make sure your providers don’t think that they will be billing your payers for the time they spend tweeting or posting. 

While CPT® created the following telemedicine codes, and some payers recognize and pay on these coders, your social media marketing won’t qualify for billing them: 

• 99444 — Online evaluation and management service provided by a physician or other qualified health care professional who may report evaluation and management services provided to an established patient or guardian, not originating from a related E/M service provided within the previous 7 days, using the Internet or similar electronic communications network
• 99446 — Interprofessional telephone/Internet assessment and management service provided by a consultative physician including a verbal and written report to the patient’s treating/requesting physician or other qualified health care professional; 5-10 minutes of medical consultative discussion and review
• 99447 — ... 11-20 minutes of medical consultative discussion and review
• 99448 — ... 21-30 minutes of medical consultative discussion and review
• 99449 — ... 31 minutes or more of medical consultative discussion and review.

“Telehealth and telemedicine really has specific requirements that have to be met in order for the visits to be recognized as something that’s billable ... and something that we always considered a doctor-patient or clinic-patient event or facility-patient event,” Miller says.

Bottom line: Remember that social media networks are meant to supplement traditional medical care, not replace it. “They aren’t a place where you can go and get the answer and not have to take the extra steps of seeing the doctor or going to the hospital or going to a clinic,” Miller explains.