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Best practices for cell phone usage - in home

Rochelle Garcia 3 years ago in User Group Help updated by Ben Simpson 3 years ago 4

For agencies that are doing in-home and/or community work, does your in-home staff give clients their phone number or do they use a service like Google Voice?  Do you provide cell phones for in-home staff?

Hi Rochelle,


Most if not all of our clinical staff have Google Voice. They give the client this phone number. We have a company policy against using personal numbers for any sort of client facing activity.  


Ben,

I'm assuming your staff use the "voice to text" feature? I like it for my personal use, but is it secure, HIPAA compliant for client info?

Thanks!

Kim

Hi Kim,


Staff can use the Google Voice application for either text messages or phone calls. 


As for compliance, the FCC's rules on HIPAA and telephone use states that, if a patient provides a contact telephone number to a healthcare provider, the provision of that telephone number constitutes express consent for telephone calls to be made. So, consent is taken care of. (https://www.fcc.gov/document/tcpa-omnibus-declaratory-ruling-and-order)


The other compliance issue is that Google Voice is not covered by Google's BAA. But, the patient data is traveling in the same way our phone system does (we use VOIP) and such transmissions are not covered by the HIPAA BAA requirement, thanks to this §160.103 carve-out: 


"Certain transmissions, including of paper, via facsimile, and of voice, via telephone, are not considered to be transmissions via electronic media if the information being exchanged did not exist in electronic form immediately before the transmission."

Yay! In conclusion, I think using Google Voice is well within HIPAA regs. 

We supply company cell phones for our in-home staff.