Health Information Management

HIPAA Q&A: You’ve got questions. We’ve got answers!

HIM-HIPAA Insider, May 5, 2014

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Submit your HIPAA questions to Editor Jaclyn Fitzgerald at and we will work with our experts to provide you with the information you need.
Q: Regarding PHI exchanges on SMS, should we be keeping logs of those texts somehow?
A: It would be difficult to log all SMS traffic if some of that traffic is sent from personally owned mobile devices that are also used for business and clinical purposes. The SMS traffic would be traveling through your workforce's personal mobile carrier and not the company mobile carrier. If you are able to track traffic through the company carrier and the devices are company owned, it's a good idea to periodically monitor SMS logs. This doesn't mean you need to keep the text of the messages, especially following an audit cycle.
Some CEs and BAs send SMS messages out using automated tools. It's a good idea to document the types of messages sent via SMS (e.g., name, appointment reminder, wellness prompt, etc.). It's also a good idea to document the content (e.g., "You have an appointment with Dr. Smith on …") and what prompts the message to be sent (e.g., upcoming doctor's appointment).
In that case, the SMS log documenting sent text messages should also be reviewed periodically to ensure messages are going to the right person, the content of the message is accurate, and that the recipient still wants to receive those text messages.
Editor’s note: Chris Apgar, CISSP, president of Apgar & Associates, LLC, in Portland, Ore., answered this question for HCPro’s Briefings on HIPAA newsletter.

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