Online Marketing, Social Media, and HIPAA Regulations- Episode 2

you hey everybody is John Schumacher here with health jams and today we're chatting about online marketing social media and HIPAA so if you're a health care provider who has any questions at all about HIPAA regulations licensure Rick other regulations in the health care industry and you're using online tactics online marketing or social media to post about information in your area so be a great conversation for you today so today I'm joined by my co-host Michael bloom as always Michael want you just say a quick hi go ahead hello everybody good evening it's so great to have you here I'm so excited for this edition of health geum's this is such a great topic that I'm looking forward to learning along with you just one of what you know for housekeeping there is a chat box for those of you attending live feel free to type your questions and comments along the way I'm going to be keeping track of the chat as well as participating in the wife discussion and we will be talking probably for about 30 minutes the group of us here and then we will get break into your questions so we definitely want to hear from you this is our casual interactive forum it we're so glad to have you and I can't wait for John to introduce our guests perfect perfect thank you Michael Michael be hopping in during some of the conversations when the questions here today and yes our guests we are lucky we are fortunate to have David Harlow who is a healthcare attorney with over 25 years of experience in the healthcare industry it's got an extensive background he's a thought leader a blogger in the industry he's got a lot of knowledge on regulations on law when it comes to online tactics in the healthcare industry so David thanks for coming on man what we'll do is just have you start off by or let me just give a quick disclaimer before i introduce you here almost forgot that this is just general information so please if you have a specific quarry or specific incident please consult with your own attorney or consider hiring david's firm as David's done a lot of work in this industry with both individuals and healthcare businesses so now that that's out of the way David let's bring you on I just just start off by sharing a little bit about you your personal background and we'll jump into the questions thank you very much for having me on I am as you said a health care lawyer and consultant and I have worked with health care providers one way or another for about 25 years i started my legal career as a real estate lawyer and i like to say that's helpful in my background because most health care is provided indoors although recently what i found is that more and more health care as being provided online and as that tectonic shift has been taking place in the industry I've really undertaken a shift in my practice and I'm working a lot more with folks in the online space and fewer and fewer of the folks I work with are building new hospital wings these days the effort is really in building out the online space the electronic tools the patient engagement in ways other than bricks and mortar right absolutely there seems to be a huge shift towards even hospital systems i believe using social media i've heard of a couple companies or a couple hospitals it was at the Mayo Clinic David who was doing that or or somebody who would they were actually building specific social media groups to impatience yes that's right as a matter of fact among the external advisory board for the Mayo Clinic center for social media and they are really leaders in this area Lee AC and his team have really taken a step way out in front to deliver information in a useful way to people where they are which is really what you need to do in any industry and health care is a little late to the table particularly because of concerns about private information being broadcast in public settings right and are you seeing like trends in addition to larger hospitals but individuals practitioners small businesses are they are they using these tools are you seeing are you helping these people and are you be seeing an increase in in their usage of these tools as well oh absolutely it's not just the large academic medical centers I mean a place like Mayo can have an event where a surgeon who's you know the only one in the country who does a certain kind of a surgery can be on the spot and available to connect with people via Twitter for a one hour tweet chat for example but the same tools since this is the such a democratization of the technology these days the same tools can be used by a small physician practice in a suburban location that is focusing on a Pediatrics let's say or I know a pediatrician and a relatively small practice who's done a series of videos posted on YouTube about when new parents should not bother to bring their kids into the office I love good not that he doesn't want to see them but at a certain point bringing a baby n you're exposing the baby to more infection but necessarily and really it's you know the nervousness of a new parent and you can address that in other more effective ways so the tools that we have at our disposal today are just tremendous and the issue is learning how to use them appropriately at either end of the spectrum in terms of size and sophistication of practice and everywhere in between right not the argument with for telemedicine right and using technologies people you know don't have to come in for oh my have a little bit of a headache what do i do I go to see the doctor or you know you can consult with people you know remotely more which is going to be a huge cost saving factor for the health care industry and as well right I mean just there's just so much too many visits happening that aren't needed you know that aren't needed and they can be more appropriately you know triage and dealt with in a remote setting remote context even medicare has a last week rule will be officially published as a draft rule tomorrow that they're going to pay for more physician services provided through telehealth and go awesome awesome so what are some of the key issues like that we face as health care providers when it comes to online tools social media use in any setting whether large or small that we have to think about to keep us on the right side of the law sure well the key issue that comes to mind first is privacy so many of the social media platforms that we're talking about are in fact public platforms some of them have some private features that you can opt in to you can set up a private group on Facebook you can set up a private chat you can send a direct message on twitter but the question is how private is private is it really private is it private enough to pass the test of being compliant with HIPAA and that's everybody's bugbear is HIPAA I can't do it because of HIPAA I can't do this because a hip I can't do that because of HIPAA basically I've found that in every every few years or so there's another health care law or regulation that comes along and people who don't want to do things blame the new law and say I can't do it you know this year it's because a HIPAA 10 15 years ago it was because of anti-kickback law is fraud and abuse can't do it can't possibly do it when in fact with a little work a little digging you can often get I have found at least ninety percent of the way there you may not be able to do exactly what you set out to do but you can do something pretty darn close almost always and that I think is a lesson that people need to hear loud and clear there's possible to work within the guidelines so in the HIPAA context what does this mean so even if I wanted to use an open communication platform or something that wasn't a hundred percent secure or private the bottom line is that the HIPAA rules exist for the protection of patients so if a patient consents to a conversation in a non hundred percent private on a percent secure setting it's up to the patient okay so we can basically wave that well if you go to a new doctor you you your your hand at a ten page form that you're supposed to sign a receipt for a notice of privacy practices and one of the things that those forms don't say is dear patient would is it okay with you if I text you is it okay with you if I tweet you is it okay with you if I communicate with you in ways that are not traditional for health care providers and the laws in the regulation permit that but general practice and the health care community just don't they don't know k so I mean as far as let's just go through a couple things couple things pop to my mind and this may be a bad question i'm gonna go ahead and ask it is our is twitter okay with consent is facebook okay with consent is you know linkedin communications all of these can you there any that aren't okay are they all okay as long as the patient gets consent and how do you get consent over Twitter when the thing flies down the page you know right so I mean the question also becomes does it really make sense to be delivering healthcare services via Twitter probably not you probably want to take the conversation offline or into some longer formed setting or into for example a private facebook group there a number of private Facebook groups that organizations have set up for conversation it could be you know with the large group could we could be talking about a hundred people 200 people but just as some people are comfortable with group appointments with their primary care physician or specialist or for example a a cardiologist who can have a group appointment so rather than pumping people through you know 10 12 minutes at a time you can have an hour hour and a half long conversation if I have a question that I want to ask my cardiologist chances are every other person of my age and profile who has an appointment up with the cardiologist wants to ask the same question so why push the cardiologist through five appointments where he can't answer the question let's all getting the same room together and answer it so again you can you can put that experience online so you can have the equivalent of a group appointment online and with consent it's okay to do it just doesn't need to be public how do you get consent I mean how do you tap do you just have them click like I i consent as they click in and have it secured and then go into the facebook group and you can actually use facebook groups and in that way you could yes okay so how do they how do they consent yeah bye-bye agreeing by joining the group as a facebook group administrator I imagine you can set up a page or a tab of terms and conditions that would lay that out and you basically identify the fact that hey you know it's the Internet that's not a thousand percent secure it's pretty darn secure but you're willing to do this in order to get the benefit and folks who are active in social media who have significant health care needs are genting willing to give up a little bit of privacy in order to get better care in order to deliver better possibilities in terms of research and development to others six months or so ago there was a there a couple of surveys that showed almost a hundred percent of people who are really you know active in social media work totally fine sharing their private health information for research purposes even though two-thirds of them acknowledged that they would probably have repercussions in the areas of employment and insurance and other things you know because even though even though that's illegal I mean we have rules against that but there certainly pretexts that people pull and say well you know sorry you're no longer insurable or we can't hire you or whatever whatever and they'll give an excuse but the you know that so at some point in the future maybe we'll get beyond that I don't know okay so basically to boil all of that down into like a takeaway message for everybody listening to this today it's okay to use social media groups if you haven't want to gather up a group of people to your cause that's okay as long as they consent to doing that that's right now many platforms are now creating more secure settings so for example one of the telehealth areas that is now going to be reimbursable by Medicare is our psych services so you can have a skype or other maybe a little more secure than skype i don't know the security issues around skype in particular but you could have a secure video chat with a psychotherapist and that would be reimbursable by medicare right and i was just going to ask that actually about video conferencing because i know a lot of people would like to see clients remotely but you can't see them across state lines is that cannot just want to make that point right like you can't do telemedicine if you must you have a license in the other states right good points that's a that's a very much a live issue now with the federation of state medical boards the AMA has way down on this issue and there may be some some movement in the future to make it easier for someone licensed say in Massachusetts to see a patient remotely in New York but right now you really need to get two licenses so there are people who have I mean I know people who have 25 different medical licenses in different states so that they can provide services through telemedicine tools to folks in all those different states right right now do you see that changing do you see it's heading that way or is there too much at stake at state for each state to keep their lessons or separate right there's a lot of you know in any sort of professional licensure and credentialing setting there's always the danger of the medieval mill medieval guild mentality creeping in and sort of protectionism but I think we're getting to the point where folks will recognize at the state medical board registration level that if you're licensed in Massachusetts you're probably ok enough to be licensed in New York and they'll incorporate some sort of reciprocity okay right right as far as actual name dropping some video platforms I don't know about skype I don't know if they're HIPAA compliant III know its services service called VC I don't know if you've heard of that one David it allows HIPAA compliant video conferencing and then I think Google helpouts as a setting for that I was just talking to a gal the other day about that and Ryan ink and I you could correct me if I'm wrong here that you can or you're allowed to use Google helpouts which is a little different than hang out with same platform but a different style are set up I guess you could say to conference with people and it's considered HIPAA compliant that correctly um I'm not positive about the Google helpouts but VC and there are other platforms there are other telehealth platforms that can be used and some that are white labeled to healthcare provider organizations okay John could you spell out that video sir oh god let me open another browser and look real quick here we don't have to do it right the second baby good for people to be see I think is what it was called anyways drop it on the replay page so i think it's v vsee i believe the SE e yeah I think you're right David I think you're right now let me see here let me go and confirm that real quick yeah but the point is is that there are there are rules and the rules are there to protect patients and sometimes we forget that they're there to protect patients and not to just create barriers that's not to say that everything in the universe is waivable by a patient but there are things that that may be waived by a patient and there's you know certain amount of common sense needs to go into this as we said before there's certain messages that you might not want to send out on Twitter there was an example in Boston a couple of years back there was a city councilor who heard shots fired while he was in a neighborhood at a neighborhood meeting and his cell phone was about to die and he decided he didn't have enough juice and his phone to call 911 so instead he tweeted the fact that he heard shots fired at such in such a location and he was sort of relying on the fact that he thought he had enough engaged followers that somebody else would pick up the phone and dial 911 right and he got in trouble for that yeah that's not a really good idea yeah I mean that's not a sharing of a private information but it's a sharing of information it's using the tool in the wrong way so I guess is my point there there are tools that are good for certain things and just not good for other things and if you're dying to use Twitter all the time you think everything is tweetable that's not necessarily the case I think you need to be flexible and use the right tool for the job just as you would in using these tools for marketing and other sorts of engagement purposes certain tools are better at doing certain things and you always want to keep that in mind all right all right so we move on to the next question Michael sure I just been I just want to say first I'm really excited to hear about the changes in Medicare for making telemedicine more accessible because I know as somebody who supports a lot of caregivers who are caring for elderly loved ones even taking some elderly folks to medical appointments can be a drag on in terms of you know just an inconvenience distance people have frailty so if there's the ability to be able to communicate with the medical team without always having to travel in physically to an appointment I just think this opens up such a wonderful wonderful service to better care for folks and even the mental health arena you know the same thing a lot of pee miss psychiatric appointments I used to serve people with disabilities for many years and I know people wouldn't just go to their appointments so often if they were able to do it right from the comfort men for their home without travel appointment suck um you know completion would probably go up right yes yep I'm sorry so anyway I was just wondering you know just because I know we're talking about HIPAA and I think it's great to think about all the flexibility that we can have based on make it easier for patients and their patients can or clients that we have can give permission I'm just wondering if there's any other sort of laws regulations either within HIPAA or from outside of HIPAA that has health care professionals we should be thinking about sure so there are other rules and there are also other agencies who enforce rules including a little bit of a turf battle going on these days between health and human services and the Federal Trade Commission in terms of enforcing HIPAA and some folks in the healthcare arena have gotten slapped down by the Federal Trade Commission which is you might be surprised to hear as opposed to health and human services for HIPAA violations privacy violations so that's something to be aware of and concerned about and or there are also other rules there are other kinds of records and services that don't rise to the level of being covered by HIPAA in this day and age we have a lot of people using personal trackers of one sort or another that are connected to the internet or that can be from which data may be uploaded to other repositories and so forth and so on and those repositories of data that's gathered let's say from your Fitbit or something like that people think of that generically as as sort of a health related data and might think that that's covered by HIPAA but it's not HIPAA covers health information that is going into or out of an electronic health record maintained for a patient by a health care provider or a health insurance company okay so there's a lot of other stuff flying around that's out there it's not covered by HIPAA doesn't mean that it's not covered by anything there are breach notification rules that cover that kind of data that are enforced by other agencies federal trade commission again there are state laws that differ from state to state their state laws that cover different kinds of data if it's a quote-unquote sensitive data which means different things in different states it could be subject to a whole host of other state related rules and regulations even if it's not subject to HIPAA at all any personal data of certain kinds of subject to privacy rules even beyond health care data financial data other information and we keep hearing about all this data being lost or breached and so it's important for folks getting involved in this one way or another to be aware of the whole variety rules that are out there okay all right so a lot of our listeners are that solo practitioner or the small business person what's just give us like one takeaway that they should look out for and then we'll move on to maybe a couple key studies well the real issue is to think about what information are you sharing what platform are you sharing it on and and think about the coffee shop rule if you wouldn't if you wouldn't talk about it in the loud voice in the coffee shop you probably shouldn't be posting it on an open forum online okay all right so let's go through a cup like a case study let's just give a couple of examples before we get to the Q&A part of the the webinar here and let me just throw this out here so let's just call somebody bill let's say bill is a physical therapist and he's not sharing patient-related potentially patient related content but it's simply building let's say an information product where he helps other physical therapists with a task or a business situation if there any if that makes sense but are there any rules or regulations regarding HIPAA regarding privacy that he would even need to worry about if he's not using any other data from it from a client or patient in that case well in this example we're not talking about patient data at all right the the situation may implicate other kinds of issues like licensure issues like is is this person training folks in the same state state where he's licensed to practice is he training people in other states does he have to be providing that information only if he's licensed in another state certainly would if this were sort of a continuing education thing where somebody has to get continuing education credits in order to satisfy a licensure requirement if it's more of a business coaching situation that I would say it doesn't really matter if he's licensed on the other state you're taking in information someone who's attending his course and we'll use that together with your professional knowledge that subject to local licensure in order to build out a broader range of services in your own practice so for b2b businesses like my example where he's basically packaging his knowledge on an online medium and sharing it with another therapist would with that wouldn't have anything to do with HIPAA but it may have something to do with license your laws maybe it's hard to say it out there depend on the clinician right in their state and all their well I mean if you know if you were trying to get continuing education credit for this seminar let's say then that would be an issue if not then you know let it go good luck right nothing nothing really legal overall to worry about no no not at all ok let's good to know because I think a lot of like myself at least my was a physical therapy starting off I was creating ebooks on pain relief right and in selling them and doing things like that and you know not necessarily there's licensure issues I think you need to be aware of which I had to look into but not necessarily any larger national hippo type rules it was that that's correct right because again we're not talking about patient data and tip exists to protect the patient so even if even if it's York like for my case teaching a potential patient and exercised through the internet there's nothing that HIPAA there well that's a different situation and what I had understood you to be asking is a physical therapist teaching other physical therapists if you're talking about teaching a patient then the question is are you providing a professional service that is subject to state licensure and are you are you able to initiate the patient provider relationship remotely so in the telehealth context we've talked about on the on the fit at the physician level some states take the position that even if you're licensed as a physician in my state you are not able to initiate a patient is a physician-patient relationship by video you can only initiate that in person and once you've once you've initiated that you can provide services remotely ok so this recent case in Idaho that plays on that fact and the the bottom line is that the board is very protective of the profession and is not happy about seeing interlopers get involved so in the context of providing any sort of service or therapy online or via some sort of video medium telehealth medium the issue is going to be are you licensed to provide service where where the patient is located right and to have you appropriately initiated if clinician patient relationship right and does that same thing apply let's say if I didn't see them via videoconference if I just simply say wrote a book on pain relief and sold it to them would that be that would be different correct right because you're not you're not professing to have a one-on-one of clinician patient relationship now you can have a one-on-one communication that is clearly labeled let's say as you know this is not medical advice this is not health care advice we're just chatting here just as you as you did so kindly for me at the top of the hour this is not legal advice I'm just talking yeah ah and you know they say free advice is worth what you paid for it but the the issue is that for a for a clinician to be able to deliver or a professional opinion to deliver professional services there has to be a professional to patient relationship established now just as an example and following on in the example you're giving I have clients who create platforms for the delivery of information that is not health care okay so someone who is I'm can use the platform for a clinician who's licensed only in state a to provide information to people who are living all over the country but it's information it's not medical services so this is like a blogger or something like that they're putting out their advice or their knowledge but they're not you know in calling that medical advice so basically you if you if you're going to see people face to face and engage in that you need to know your state laws you need to understand you know where that is and even with that can you clarify it not met pickle advice and get away from your license or does that depend on the license in the state and everything well it depends on the state because every every state interprets these things differently but in in general it is possible to provide you know sort of genericized advice that is disclaimed you're saying this is not medical advice and the example I'm thinking of as a client that has a phone a smart phone app that can snap a picture of a skin growth and have it zapped over to a dermatologist dermatologist looks at it not diagnosing the patient but the dermatologist can say back you know looks to me like that might be XYZ if I you know if I were you I would get the following over the counter pointment use it if it doesn't clear up in two weeks to your doctor mm-hmm I think it'll clear up in two weeks that's very different from diagnosing a disease and prescribing a prescription medication right right so there seems like there's a lot of semantics a lot of gray area still a little bit you know within that let me let me get you with one more example before and I'll try to be quick as we might be going a little bit over guys but hey let's just it's what it could be this is good stuff what's that Michael I said we have a few questions that come there too yeah so um so let's just say let's just give another example like a nurse practitioner for example who it wants to be an advocate for somebody who is status post a certain surgery or something then and that person has a passion for that advocacy and wants to create you know website products write books do speaking engagements and create like an online following is there any I know it might be kind of vague but is there any issues there that they need to think about because they are technically being an advocate for a group of people I guess that would probably be situational depending on if they're working directly with them or not can you touch on that David right well I think what I hear you saying is somebody who wants to have an online community and host some online information about a particular condition or set of conditions right yeah and create let's say create a membership site or creates you know ebooks and sell sell stuff online and things like that around that build a community that's kind of things right absolutely I don't see anything wrong with that and again as it happens I have clients of doing things like that as well and the the line is is this it's not you're not providing health care services through this platform you're publishing information that happens to be written by a doctor based on the reputation of a particular doctor people will lend that you know more or less weight and this opportunity to share information to share experiences once you create this online sort of community patients will contribute information about their own experiences or I tried drug X you know it's off-label use and I have good experience with it I don't want physicians in my community saying things about that necessarily or maybe that's going to be okay as a certain point but patients can certainly share their experiences and there's big disclaimers on the website that say this is not medical advice and that's and that's enough to say you know I even though you're licensed professional I'm building a website i'm putting out information and knowledge that i have its this is disclaimer technically not medical advice right now because that's not it's not directed to an individual patient got you based on an individual set of symptoms okay all right I think that's pretty clear then so basically if you're engaging one-on-one with people think a little differently than if you're just putting out information to larger groups that kind of a breakdown of that that's right okay all right all right David well hey that was good stuff man I was like I'm excited about that that's a that's a lot of neat information they're always kind of wondered about these things myself and so I just kind of spit none out but let's get it let's go over let Michael we got a few questions it was a link we do I'm excited to share them let's go over to that and see what we can do here Marie well a couple of them have to do with clarification from some of the Greek anecdotes and examples that were shared earlier so I just want to go back for a moment I'm from dawn David you in just a question from dawn you told the story earlier about the guy tweeting about shots that were heard and her question was why wasn't tweeting it inappropriate platform and whose privacy to e breach well I was just using that as an example of maybe not the best choice of platform it's not a privacy issue although let's say let's say let's let's take it to a different situation using Twitter where um yeah a hiker who is trapped with this foot under a rock there's nobody around for miles what does he do tweets a doctor who he knows or sends out a general tweet let's say sensitive general tweet you could have a doctor tweeting back and forth with an individual stuck in the back country but somehow still getting a cell signal who and the and the doctor could tweet instructions to this person on what to do because you have this emergency right so emergency is sort of Trump HIPAA and people sometimes forget that I'd rather have some doctor tweeting instructions I mean in an extreme case tweet instructions to somebody and how to amputate their own foot so they can get down off the mountain and not die of exposure then be concerned about the privacy issues inherent and tweeting back and forth about something like that right the you can always get a consent later and sometimes people forget that particularly in more sort of normal day-to-day emergency room situations okay great create that makes total sense and we have a great question here from Jessica um that she's created an app that helps people self monitor their eating disorder recovery they can log their behaviors substance used and emotional state the data is not connected to a server at this point however the user can send a PDF to their treatment professional therapist or nutritionist via email if is the treatment professional in violation to hip up by getting this communication yeah again as I said the HIPAA rules exist to protect the patient but they're sometimes held up as barriers to communication by providers now there are other institutional reasons why providers want to be careful about how information is communicated to them and as I said before you know it's okay to tweet back and forth with your doctor if that's okay with you or text back and forth i should say with your doctor if that's okay with you but one reason why a doctor or an institution might not want to do that is that well what about continuity of care so we're texting back and forth so i have the whole conversation on my phone doctor says but when i'm off next week on vacation who's going to pick up the ball how's that going to work and depending on the institution and on the physician they'll say hey you know we'll figure it out we'll make it work I have a patient who's actually communicating with me and wants to get better that's great I'll other patients don't want to talk to me I can't get through to them I can't make them better and by the way as a healthcare organization that means they're going to cost me more money later so at a number of different levels it really makes sense to communicate with people in the way they want to communicate and the example that you gave is not a HIPAA violation because a patient faxing to a physician information about him or herself that self-generated herself recorded that is that that's that's patient information being provided to the physician does that go straight into a medical record well if it's just facts information that doesn't fit a particular field in an EHR no it's not going straight into a medical record it's going to some kind of notes file and in the battle days it would just be brought in on paper and you know delivered or mailed in it may be part of the electronic it may be part of the medical record once the physician gets it but it's treated differently because the provenance of the data is from the patient right so it's not a lab result from a reference laboratory it's patient provided this information now some health care providers are scared to death of that kind of information for some reason but when a patient comes into their office they're writing stuff down that is patient generated information just happens to be conversation as opposed to actual data and I think as a as a as a community the healthcare community needs to be more willing to accept data from patients at face value all right that's great our next question I'm going to kind of stay with the theme late now this comes from Katherine I asked my followers to hear their experiences with hot flashes and night sweats I had a few responses for women who volunteered this information is this a valuation of any sort this is not a private group is this person a clinician I don't know Katherine if you could just type in and clarify what your role is in in that area that would be great just type that into the chat so basically if they don't have a license or not a licensed health professional they don't have to worry about hip at all right that's correct that's correct but so in a friendly conversation like that people can volunteer whatever they want people understand for the most part that these things are open and public although sometimes people people seem to forget that the other thing is even if even if we're talking about a licensed professional the setting of the conversation should clue people in to the fact that this is not a private conversation best-case scenario would be to highlight that specifically at the beginning if this is some kind of tweet chat now we're asking you as always to share some information tonight but please remember it's public forum okay Jay we have a few other questions that come in here too that we here I one another one from Jessica if a user or a patient gives a testimonial to your product via Twitter or Facebook do you need their consent to post this on your website I think that it would be a good idea to ask for that consent I think most people having tweeted something publicly would be flattered to be asked but I think of the better you know better judgement would be to ask it is tweeted publicly it's out there in the public domain I don't think you really need to as a legal matter but if you're going to associate somebody's name with your product or service and a non-transitory matter because Twitter you know the things just fly by and then you know people think you'll will know I'll never see that again if it's going to be there in some permanent way it makes sense to to talk about it first get to the right it's great Catherine did clarified that she's not a waste its professional um she creates cool cooling scarves so Wow no I'm still really really great to take you katherine for sharing and these were some great questions that have come in perfect perfect all right well I guess unless there's any other questions I think there's a couple back there I think it's pretty much we pretty much got to the main ones so David thanks so much I mean just share with the viewers here where they can find out more about you if they're interested in getting advice from you or finding out more about where you're at sure so I practice at the Harlow group and I'm online at Harlow my twitter handle is on the screen health blog BL AWG and that is also the name of my blog health blog com and I right there about health care policy and law issues as as they come up and as they strike my interest and I can be reached through any of those platforms sounds good alright and then I think that we have one more question pop in there Michael or I think the question it just popped in was what if it was just a first name that used as a testimonial do you still need permission if you're not fully identifying the person um you know I mean I think that maybe something broader discussion and sort of what sort of credibility you get by not using a full name but if you don't have the identity of the person who's giving the testimonial I've sort of questioned the value of the testimonial okay all right I would agree with that as well I know just add in here in something I was going to type into the chat but something I like to do is at least get an email reply or something I can save it records it says that this person is okay even if they only want me to use their first name you know a lot of times I will just use first name last initial not to fully identify the person I at least want their permission yeah no no that makes such yeah I think just to emphasize something I've been saying all along it's really up to the individual people use HIPAA and other laws as reasons to not engage and I think it's very important to be open to engagement and communication and much of the health reform law that has been debated and talked about over the past number of years is really at its core it's about patient centeredness and patient engagement and for the first time ever the words patient engagement and patient centeredness are in the united states code and that's just phenomenal and that is an opportunity for all of us involved in health care one way or another to use every tool at our disposal to engage patients in their healthcare and it's certainly a lot easier to do with the tools at our disposal just got to do it right all right okay all right everybody well thank you so much David for sharing that today and and coming on our show and chatting about some really important issues it's a great discussion thank you so much pleasure thank you yeah and everybody is on here still we just want to let you guys know that you know obviously this is the online marketing forum for healthcare entrepreneurs so Michael and I are opening up our schedules for three actually Scott think three slots Michael up to take a look at your business your online website your whole marketing process there if you are online doing social media doing website type work Michael and I have been doing that for a little while now and we have some definitely have spent some some money and time learning that so if you're interested in having us look at your setup your website for free go ahead and email me at John jaaon at new wave healthcare com all right anything else guys I think we're Michael E good at fabulous discussion I'm so pleased to meet you in person tonight David yeah thank you my pleasure gentlemen all right good night everybody you you

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