Patient access managers who question whether a separate consent is needed to contact patients regarding appointments or pre-registration can be reassured by a new ruling, according to Michael Sciarabba, MPH, CHAM, chair of the National Association of Healthcare Access Management’s (NAHAM’s) Public Policy and Government Relations Committee. Sciarabba is also director of patient access at UCSF Medical Center in San Francisco.
The Federal Communications Commission (FCC) issued a Declaratory Ruling and Order this year that clarified the Health Insurance Portability and Accountability Act exemptions under the Telephone Consumer Protection Act of 1991. “In patient access, there was a lot of confusion about what was exempt, because the way we communicate today is very different,” says Sciarabba.
The FCC found that an individual’s voluntary provision of his or her cell telephone number to a healthcare provider constitutes prior express consent to be called on that number. Acceptable calls that fall under the exemption include appointment reminders, hospital pre-registration instructions, and preoperative instructions.
“When we are provided contact information from the patient and obtain the general consent, we are getting an implied consent for those activities,” Sciarabba explains.
Sciarabba says the ruling has sparked a lot of discussion among patient access leaders about how they do reminders, and it has caused them to examine their processes closely. “Do we need a specific consent? No, we don’t, but we still need to follow best practices,” he says. “We still need to be concerned about patient privacy.” Sciarabba says patient access should be “very thoughtful about how we are doing reminders.” He recommends:
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giving patients options on how to receive this information;
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informing patients they can opt out if they choose;
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documenting reminders in the admission/discharge/transfer system.
“The ruling does give guidance that reminders should be short and concise, and we shouldn’t be reminding patients numerous times,” says Sciarabba.
NAHAM members are reporting that patients increasingly prefer text messaging reminders and give patient access a cellphone number as a primary contact, he notes.
“It’s critical that we in patient access allow patients to decide what kind of reminder they want, if any at all,” Sciarabba says. “This is about the patient experience.” (The FCC’s Declaratory Ruling and Order can be accessed at http://fcc.us/1fD48Ta).
SOURCE
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Michael F. Sciarabba, MPH, CHAM, Director, Patient Access, UCSF Medical Center, San Francisco. Phone: (415) 514-5724. Email: [email protected].
