10.5 Appendix E – Examples of Text Messaging Policies for Partner Services

MULTNOMAH COUNTY OREGON
HEALTH DEPARTMENT CLINICAL STANDARDS
SECTION: Community Health Services
CHAPTER: General
ORIGINATED: 05/17/2012
TITLE: Using Google Voice for texting (SMS) clients for Partner Services
Applies to: Disease Intervention Specialists (DIS) staff in the STD Prevention Program

Purpose Statement

Text messaging (SMS) can be an effective method of contacting individuals that are difficult to reach and do not respond or answer phone calls.^1,2 Text messaging is not a secure method of communication and text messages are subject to public records retention laws. Therefore, staff should limit the use of text messaging to those when clients do not respond to phone calls.

The purpose of sending a text message is to engage the individual in a voice call or face-to-face conversation or to inform a client of an appointment time or meeting place or missed appointment. Protected health information (PHI) must never be sent via text messaging.

The texting guidelines are used to provide Disease Intervention Program partner services. Studies have shown that partner services are cost-effective and cost saving, and the many benefits extend to the people living with HIV or other STDs, their partners and the larger community as well. Providing timely services is a core component of our program.³

Procedure for texting clients via Google Voice

• Confidentiality is of the utmost importance. Sending a text message carries the same risks as leaving a message on voicemail or an answering service. Because messages may be viewed by people other than the intended recipient, make sure the content of the text message is appropriate (see Initiating Text Communication).
• Caution must be taken to ensure that staff have the correct phone number and that the correct number is being used for texting.
• All text messages must be sent using Google Voice Text via the account and number that is assigned to the user.
• All text messages sent or received will be documented and stored by Multnomah County in accordance with record retention requirements. See Documentation below.
• Clients must be informed to never send PHI to Multnomah County via text messaging.
• Do not erase any text messages, the messages will be stored by Multnomah County in accordance with record retention requirements. See Documentation below.
• Text messaging is a rapid means of communication and timely response will be anticipated. Be prepared to respond immediately.
• If the individual responds with a text message, respond with another text message asking the individual to call you.
• Be aware of the tone of your text. It is extremely difficult to discern tone in text messages. Remain professional at all times.
• Text messages are limited to 160 characters (including spaces). If a message is over 160 characters, most cell phone carriers will split the oversized message into two messages.
• Be aware that some people do not have a text messaging plan as part of their cell phone service and they may be charged for each text message that is received.
• If text messaging is being used to contact an individual, texting should cease once contact is made with the individual or as soon as the case investigation is completed.
• If you are using text messaging to confirm an appointment time or meeting location or to inform the client of a missed appointment, you must first obtain the client’s written consent unless as part of a DIS case investigation ⁴
• Personal text messaging with clients is strictly prohibited.

Information you may include in a text message	Prohibited information in a text message
Your name	Protected Health Information
Your County Phone Number	Information that identifies you as a health care Provider or specialist
Statement that identifies that you are from Multnomah County	Client Referral information
Request for the client to call you
Clients appointment time  (no consent if for "partner services")
Appointment location (no consent if for "partner services")
Missed appt reminder ((no consent if for "partner services")

Initiating Text Communication:

❑ Log on to Gmail account XXX

❑ Log onto Google voice with phone XXX

Examples of language to use when texting clients for partner services:

• I am Jane Doe with Multnomah County and I need to speak with you. Please call me as soon as possible at 503-988-xxxx.
• I am with Multnomah County and I have important information regarding your personal health. Please call me as soon as possible at 503-988-xxxx.
• I am with Multnomah County and I have information regarding an urgent health matter. Please call me at 503-988-xxxx.
• I have made numerous attempts to contact you. It is very important that we talk. Please call me at 503-988-xxxx.
• Your appointment with Jane Doe is at 3:00 p.m. today, call me if you have any question Juan Doe 503-988-xxxx
• Your appointment with Jane Doe is at 3:00 p.m. today at 92nd and Powell, call me if you have any question Juan Doe 503-988-xxxx
• You missed your appointment. Please call 503-988-xxxx to reschedule

Responding to Text Messages

• If a client responds to your text message with another text message instead of calling, use an approved message to encourage the client to call you.
• Never respond to a text message from an individual that contains PHI. Instead, send a new text message to encourage the individual to call you.

Examples are: 

• I am not able to give you specific information in a text message. Please call me at 503-988-3780.
• I can tell you more when you call. Please call me at 503-988-3780.
• This is urgent and needs your immediate attention. Please call me at 503-988-3780.
• The information I have for you is confidential. I can tell you more when you call. Please call me at 503-988-3780.

When you are unsure how to respond to a text message, ask your supervisor or manager for guidance. Managers and supervisors are responsible for insuring that staff understand the proper use of text messaging.

Documentation

• Text messages sent to contact an individual must be documented in the client’s/contact’s record via the STD Database
• Text messages sent to remind a client of an appointment time or location must be documented in the client’s record via the STD Database
• Text messages sent to inform a client that he/she missed an appointment must be documented in the client’s record via the STD Database
• Text messages sent from a client with PHI must be documented in the client’s record
• Document all text attempts and results in STD Database.

Text messages may ONLY be used to set up appointments or request a return phone call. Texts may NEVER be used to provide any kind of health or partner information

The goal of text messaging by DIS is to enable the DIS to expedite contact with a client to schedule a time/date to meet. Text messaging is particularly applicable in situations where a client or partner is not responding to traditional means of follow-up e.g. phone calls and/or field visits.

Text messaging can be an effective method of contacting individuals that are difficult to reach or only have access to texting service, and is particularly applicable when an individual has not responded to phone calls, letters or field visits. However, text messaging is not a secure method of communication.  Further, telecom providers are not required to protect the content of text messages and may make these records available to external parties such as law enforcement when requested even without a court order.  Therefore, staff should ensure that no confidential information is ever transmitted via text message. The purpose of sending a text message is to engage the individual in a voice call. Identifiable health information must never be sent via text messaging. (This is information that relates to the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; … that identifies the individual; or With respect to which there is a reasonable basis to believe the information can be used to identify the individual.”)

Protocol for Field Services Staff

The text messaging feature on cell phones will only be used for partner notification activity. It is not to be used for intrastate communications between staff or personal business. DIS must strictly adhere to the text messaging protocol at all times.

Confidentiality is of the utmost importance. Sending a text message carries the same risks as leaving a voicemail on a home answering machine or a Public Health letter at a client’s residence. Because messages may be viewed by people other than the intended recipient, make sure the content of the text message follows the approved text messaging guidance below.  No protected health information will be permitted in text messages.

Conducting PN through text is applicable in situations where a client or partner has not responded to phone calls and/or field visit attempts. A text message should be sent in order to prompt the person to respond. Caution must be taken to ensure that the DIS has the correct number and that the correct number is being entered. Ideally the DIS will confirm that the contact number on file is a number that is connected to a mobile phone through internet tools such as ‘reverse search’, (i.e.www.reversemobile.com). It is important to note that information obtained through a reverse lookup may not be the most current information. It is possible for a cell phone subscriber to retain a cell phone number that has been assigned by one carrier when switching cellular providers. In this case the previous cellular provider may be inaccurately listed as the current provider.

• Text messages should be sent when you are in a space that offers privacy.
• Clients must be informed to never send protected health information (PHI) to the DIS via text messaging. If a client does send PHI via text messaging to the DIS, the message must immediately be transcribed and then immediately deleted from the phone or smart device. Copies of other text messages sent or received should be retained in the mobile device and/or email account during the investigation and deleted upon case closure.
• Text messages should be utilized after attempts to contact the client by phone have failed. DIS should then send the standard Public Health text to the client (see below) to encourage them to call back. If there is no response to the text message within 1 hour of sending, DIS should attempt a field visit for clients with a documented address.
• Text messages should be sent to clients, their partner(s), or members of their social network only during the course of a public health investigation and when texting when clients have failed to respond to phone calls, when locating information is unknown, or when the client and/or partner states that texting is the preferred method of communication.
• When conducting PN via text, messages must be sent from a work phone or a work computer; personal cell phones or computers should not be used to communicate with clients or their partner(s). All cell phones or smart devices used to send or receive text messages must be password protected. Confidentiality is of the utmost importance regardless of the tools used for communication.
• As you are attempting to initiate contact, you may not send more than a total of three text messages as described below. The final message should indicate that it is your last attempt at contact.
• All messages should be as professional as possible and spelled correctly. Avoid abbreviations and acronyms. Remember that you are sending a message on behalf of the NC DHHS and all your communications should reflect professionalism. Do not send smiley faces, symbols, or use SMS or multimedia message service (MMS) to send photos or other media.
• Text messaging is a rapid means of communication and timely response should be anticipated. Be prepared to respond immediately.
• If the individual responds with a text message, you may respond with another text message asking the individual to call you.
• Be aware of the tone of your text as it is extremely difficult to discern tone in text messages. Remain professional at all times.
• For unsolicited messages: Respond to the incoming messages with a message such as: “Please avoid these types of messages. As I cannot respond to you by text. Please call me at _______. Thank you.”
• Texting should not be used to conduct any interview or counseling session.
• All communication/interaction should be documented in detail on the appropriate forms and retained in the investigation case file.

Information You May Include in a Text Message	Prohibited Information in a Text Message
Your name	Identifiable health information
Your landline or cell phone number	Information that identifies you as a health care provider or specialist
Statement that identifies that you are from NC DHHS	Client referral information
Request for the client to call you

Approved Text Message

1. Your first text message should identify who you are and/or where you work and provide a brief message and your contact phone number.

• This is (insert DIS Name) with the North Carolina Department of Health and Human Services. I need to speak with you regarding an urgent health matter. Please call me as soon as possible at (insert DIS number).

2. If the person does not respond to your initial text within 24 hours a second message urging the person to call you may be sent and it should read:

• This is (insert DIS Name) again with the North Carolina Department of Health and Human Services. I need to talk to you regarding an urgent health matter, please call me at (insert DIS number).

3. If the person does not respond to either of your first two messages a final text may be sent, it should read:

• This is (insert DIS Name) again with the North Carolina Department of Health and Human Services. I have been trying to contact you regarding a urgent health matter. Please call me at (insert DIS number). This will be my last attempt at contacting you.

4. Should the person you are texting respond with a text message requesting more information, your response should read:

• The information I have for you is confidential. I am not able to give you the information in a text message.  Please call me at (insert DIS number).

The use of text messaging to improve Partner Notification Services is a privilege that must be carefully implemented. Text messages sent from business cell phones will be closely monitored for content and appropriateness and phone/text records can and will be audited by management at will. Misuse or breaches to the text messaging policy may result in disciplinary action up to and including dismissal. Your signature below acknowledges your understanding of this policy

DIS Signature _________________________________ Date____________