Don’t Let Your Hospital’s Social Media Become a Compliance Challenge

6 minutes

The Enticement to Advertise on Social Media

Imagine that your marketing team posts an announcement for an upcoming job fair at your hospital.  Seems innocent enough, right? Potential applicants are promised an endless supply of hotdogs and free souvenir tumblers along with the chance to meet and greet the hospital’s executive team. The marketing team posts a smattering of employee pictures, portraying smiling faces with can-do attitudes that will hopefully entice people to “join your team.”

A few minutes after posting, “likes” start appearing on the post, as well as “Can’t wait!” and “I’ll be there!” It all seems to be going as planned until a scathing complaint appears on the post from a recently discharged patient.

Your marketing department stares at the screen in abject horror as they speed dial the compliance team.  Comment after comment begin to appear on the post. This patient clearly has many friends who quickly become keyboard warriors. The comments call for the organization’s immediate closure, and one post describes a person’s horrible experiences with an unruly employee back in 1982 at this very same hospital. Then, for good measure, they all begin clicking the “share” button.  What started out as an innocent social media post, has quickly morphed into a compliance nightmare for your organization.

Who Doesn’t Enjoy Free Advertising?

It’s no secret that social media has significantly evolved in the past decade. According to, as of 2021, an estimated 80% of adults use social media in some form or fashion.1  Sites such as Facebook and Instagram initially promoted themselves as a nontraditional means of communicating with family and friends, which was vastly appealing to many consumers (including myself).

Over the years, as momentum grew in social media, these sites rebranded themselves many times over and have since transitioned into major marketing platforms, enticing some of the largest companies in the world to advertise on their websites, flooding our newsfeeds with advertisements and links. In the last few years, social media influencers have dominated sites, such as TikTok, Snapchat, and Instagram and have fundamentally paved the way for businesses to promote services and advertise through endless social media avenues.

It’s no surprise that healthcare organizations have joined this social media trend and have launched their own Facebook, Instagram, and Twitter accounts to engage with patients. This is basically free advertising, right? What could possibly go wrong?

Delete, Delete, Delete?

The organization’s first knee-jerk reaction to the above scenario may include deleting the original post, thereby eliminating the problem, right? Well not exactly.

Regulatory Burden

While the CMS Conditions of Participation do not directly address social media as a means of issuing a complaint/grievance, hospitals should be prepared to address this emerging issue. Per CMS, all verbal or written complaints regarding abuse, neglect, patient harm, or hospital compliance with CMS requirements are considered grievances for the purposes of these requirements (§482.13(a)(2)). This creates a dilemma for healthcare organizations as they attempt to maintain an active social media presence on platforms that allow anyone to post unfiltered and unsolicited feedback, both good and bad.

Feedback Versus Grievance

Organizations must be prepared to address their social media feedback and determine if it’s truly constructive feedback or if it meets the definition of a formal grievance. It’s not unprecedented for regulatory bodies (CMS, State Officials, The Joint Commission) to become aware of issues via social media. They can even be (gasp) tagged in such posts or have them shared to their own social media pages.

For these reasons, it’s imperative that healthcare organizations have a proactive plan in place for monitoring their social media and addressing any regulatory concerns that may arise.

Comments: Who Really Needs Them Anyway?

For me, the best approach to dealing with the potential onslaught of negative comments (aka “bad publicity”) is by taking a proactive approach. Turn off your commenting!

Many social media outlets, such as Facebook and Instagram, allow the author to disable commenting by public users. This enables the organization to post on their social media accounts without the risks associated with patients using a non-preferred method to escalate concerns.

Solicit Patient Feedback

Additionally, many hospitals have started to solicit Google reviews from patients to boost popularity in an often-competitive marketplace. I would recommend that the organization’s marketing team work closely with clinical leadership to develop a targeting method for soliciting patient reviews. Ultimately, our main objective is to solicit positive patient experiences for public viewing and deal with any negative feedback in the privacy of our closed offices.

Overall, organizations should have a dedicated email and phone number for patients who wish to escalate concerns and minimize social media feedback that has not been properly vetted.

I also recommend the organization only having 1-2 primary sources for patients to provide organizational feedback. Overall, organizations should have a dedicated email and phone number for patients who wish to escalate concerns and minimize social media feedback that has not been properly vetted. The last thing we want is for our marketing teams to have our compliance department on speed dial.

Preparation and a Positive Social Media Experience

Unfortunately, I have seen firsthand how quickly social media commenting can spiral out of control. It can often take just minutes for an onslaught of negative comments to consume an organization’s newsfeeds and, by that time, hundreds if not thousands of past, present, and potential patients have been exposed to the negative “reviews.”

As social media platforms continue to explode in their popularity and growth, healthcare organizations who use these marketing tools for patient engagement will be forced to address these inevitable compliance concerns. Preparation and having a proactive approach to your social media strategy and content are key to having a positive experience.

If organizations fail to address potential grievances that are posted on their social media accounts, there could be significant implications, both from a regulatory aspect and a public relations standpoint.

Knowledge is Key

We all know that we can’t make everyone happy 100% of the time, and if people want to complain, they will find a means to do so. However, that doesn’t mean we have to supply the pen, paper, and public forum.  We must get smarter in how we deal with social media and its billions of users (yes, billions with an “s”).

First and foremost, your compliance and marketing teams should be best buddies if they aren’t already. Your organization should have pre-determined strategies in place that address:

  • Who can post to social media on behalf of the organization

  • What’s considered approved content for social media

  • How is commenting addressed – ON, OFF, pre-approving comments, etc.

  • Who monitors feedback

  • How concerns, complaints and grievances are addressed

Healthcare organizations don’t want to miss out on this amazing opportunity for (free) patient engagement; however, we must be smart in our methodology and research our platforms for safeguards that we can use (again, turn off the commenting!).

Now that we’ve put a damper on the hotdog social, let’s think about our next social media post, shall we?

© 2023 Chartis Clinical Quality Solutions. All rights reserved. This content draws on the research and experience of Chartis consultants and other sources. It is for general information purposes only and should not be used as a substitute for consultation with professional advisors. It does not constitute legal advice.

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