WarmRegards Blog – 08/2018 Texting for Peer Counseling Programs

WarmRegards Blog – 08/2018 Texting for Peer Counseling Programs

Welcome to the WarmRegards Blog. This blog is supplemental to the popular WarmRegards WIC e-newsletter. Our next issue, “Helping WIC Clients Access Fresh Healthy Foods,” will be released on Thursday, August 23.

Pew Research from Feb 2018 reports that 94% of people age 18-29 and 89% age 30-49 own a smartphone. Obviously electronic communication via smartphone is the method of choice by most WIC participants. It’s an effective tool to engage moms with the goal of increasing breastfeeding rates and WIC participation.

In one study, 353 women were tested to see if weekly text intervention, from 24 weeks gestation to 6 months in age, increased the rates of moms exclusively breastfeeding. At 6 months, the intervention group had almost tripled EBF rates (43%) compared to the control group (15%).

USDA data indicates that moms who are exclusively breastfeeding at six months are more likely to remain on WIC once the child turns one.

A study posted by Colorado WIC Texting for Retention shows that using a texting service to reach out to WIC participants on a routine basis improves retention rates. These studies underscore the value of using text messaging to improve breastfeeding rates, client engagement, and overall WIC participation.

Once participants have received your broadcast text messages, which are designed to be informative and generate engagement, what is the safest way to continue the two-way conversation?

Obviously training protocols are put in place so that peer counselors and other WIC staff understand the necessity of safeguarding client privacy at all times. Peer counselors know they cannot give lactation advice by text: “Use text messages only for simple, quick notes to check in with mom. Discuss specific questions or concerns by phone or in person.” (KY State WIC Texting Policy for Peer Counseling)

Why is it important to ensure that peer counselors never give personal advice by text? Discussing anything personal in nature regarding someone’s current health status (PHI: Protected Health Information) by text is a violation of HIPAA and subject to penalties up to $50,000 per violation.

The HIPAA Journal addresses the technical safeguards over texting. (“When is Texting in Violation of HIPAA?”)

  • Data transmitted beyond an organization´s internal firewall should be encrypted to make it unusable if it is intercepted in transit.

“Standard ‘Short Message Service’ (SMS) and ‘Instant Messaging’ (IM) text messages often fail on all these counts. Senders of SMS and IM text messages have no control over the final destination of their messages. They could be sent to the wrong number, forwarded by the intended recipient or intercepted while in transit. Copies of SMS and IM messages also remain on service providers´ servers indefinitely.

“There is no message accountability with SMS or IM text messages. For these reasons (and many more) communicating PHI by standard, non-encrypted, non-monitored and non-controlled SMS or IM is texting in violation of HIPAA.” (HIPAA Business Journal, 2018)

When using a standard two-way conversational texting platform, can you be assured, 100%, that your staff and peer counselors will never discuss anything deemed to be PHI?

Will a HIPAA-compliant, two-way text platform prevent that risk?

HIPAA states that a covered entity must take appropriate measures to protect PHI. A company can ensure their systems storing the client conversations are secure, but that security is gone once the message leaves the texting platform. It travels through normal SMS messaging channels through the carrier to the text recipient.

Unless that conversation with PHI is encrypted, there is no way to protect the PHI. Any system stating they have HIPAA-compliant texting is misleading. Only you (not the system) have control over the unencrypted text messages you are sending and if they are violating any rules about protecting PHI.

“The HIPAA encryption requirements for transmission security state that covered entities should ‘implement a mechanism to encrypt PHI whenever deemed appropriate’.” (HIPAA Journal, 2018)

Although WIC is exempt from HIPAA, many agencies operate as a hybrid entity covered by their departments as a covered component. How can WIC agencies ensure they are safeguarding participant data to avoid hefty penalties?

 Carefully assess text messages to ensure they do not contain PHI. Keep messages more informative and educational in nature.

  1. Appointment reminders are allowed as long as the message does not state the participant’s health condition. Avoid words like prenatal, diabetic, etc.
  2. If your state requires, collect written authorization before sending messages.
  3. Advertise a method to opt out of texts.
  4. Keep texts 160 characters or less, including spaces, and send no more than 3 per week. (Tcpablog.com)
  5. Only use encrypted chat platforms for two-way conversations, which allow for user authentication and secure sign on.

By just implementing a few protections, as identified above, communicating with WIC moms through text and secure chat apps can be an extremely effective method to improve breastfeeding rates and overall WIC retention.

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