November 27, 2023

Social media allows us to connect with friends, family and causes important to us. Working in health care, we handle confidential information from patients and members every day. Even if names and other identifiers are not included, we must be sensitive about what we share on our personal social media channels.

See below for seven real examples of employees getting social media wrong. All of them received disciplinary action, and some were terminated.

  1. The Today Show ran a story about a patient. An employee commented on Today’s post, “I worked with this patient.”
  2. An employee made a “day in the life” TikTok video, which included footage panning the camera around their workspace, capturing computer screens with patient information in the background. The employee also included an image of blood splatter on their scrub pants.
  3. A local news channel highlighted an incident in which a parent allegedly physically assaulted a school bully. Recognizing the parent, an employee shared the post and tagged several co-workers commenting, “their kids come to our clinic.”
  4. An employee posted a photo of them holding an infant patient on Instagram. The post was captioned, “this baby needs a new heart, but she’s already stolen mine,” hinting at the patient’s health condition.
  5. Two employees assisted in an unusual procedure. The situation was embarrassing for the patient. One employee “interviewed” the other employee about the procedure, posting the video to social media.
  6. An employee posted on a patient’s online obituary, “he fought so hard after his lung transplant.”
  7. After seeing a patient with measles for the first time in their career, an employee posted about their experience on an anti-vaccine Facebook group. The story was of great local interest, and, in their attempt to get more information on the case, local news stations set up tents outside our facility.
So what should I share?

The key to striking the right balance between being an active, engaging professional on social media and upholding the highest standards of ethical conduct is knowing what you can and cannot share.

  1. General work statements such as “I love my job at Texas Children’s” or “today was tough” or “we’re having a busy flu season” are acceptable as long as confidentiality of patient/member information is maintained.
  2. Professional achievements and milestones, such as completing a training program or obtaining a certification, deserve to be celebrated!
  3. Work gatherings and celebrations are great for social media! Just keep things work-friendly and be cautious of the surroundings you capture.
  4. Health and wellness advice, like tips for maintaining a healthy lifestyle or preventative care, is fine to share if it’s not tied to specific patient/member cases.
  5. Expressing empathy and offering general condolences like “get well soon” and “sorry for your loss” are appropriate as long as comments don’t indicate a professional/clinical relationship.
  6. Maintain professional boundaries and use discretion when connecting with others…comment sections can get heated, so keep conversations respectful and always be cautious when sharing work-related information.
  7. Consult with your peers if you’re unsure about a social media post – it’s always best to double-check before sharing any content that might be questionable.

Need to read the fine print? Texas Children’s has several policies related to social media behavior and etiquette:

Concerns? Texas Children’s does not tolerate retaliation for reports or concerns made in good faith. If you have a concern about any suspected unethical, illegal or questionable activity, you should report the concern to:

  • Your immediate supervisor,
  • The Compliance and Privacy Office at 832-824-2085, or
  • Texas Children’s Confidential Hotline at 1-866-478-9070 (available 24/7)

Questions? Contact the Compliance and Privacy Office at 832-824-2085 or compliance@texaschildrens.org, or HR Employee Relations at 832-824-6721 or employeerelations@texaschildrens.org.

October 31, 2023

At Texas Children’s, our commitment to creating a culture of ethics, integrity and compliance with all applicable laws, regulations and policies is directly tied to upholding our organizational mission. We hold our workforce to a high standard of ethical conduct, and encourage team members to lead by example and always do what is right.

Compliance and Privacy Week is November 5–11 and you’re invited to “Be a Compliance Champion!” by engaging with the Compliance and Privacy team and shredding your documents on Shred Day.

Coffee with Compliance: Have questions or want to learn more about how you can help? Stop by to chat and enjoy some coffee with a representative from the Compliance and Privacy Office. Participants will be entered for daily drawings and giveaways!

  • Monday, Nov. 6: Meyer Garage 19 (6 a.m. – 9 a.m.)
  • Tuesday, Nov. 7: West Campus – First Floor (6 a.m. – 9 a.m.)
  • Tuesday, Nov. 7: Meyer Building – Lobby (12 p.m. – 2 p.m.)
  • Wednesday, Nov. 8: Medical Center Campus – The Auxiliary Bridge (6 p.m. – 8 p.m.)
  • Wednesday, Nov. 8: Health Plan – 14th Floor Board Room (8 a.m. – 11 a.m.)
  • Thursday, Nov. 9: Feigin Tower – First Floor Lobby (6 a.m. – 9 a.m.)
  • Thursday, Nov. 9: Pavilion for Women – Fourth Floor (11 a.m. – 2 p.m.)
  • Friday, Nov. 10: The Woodlands – Main Lobby by Donor Wall (6 a.m. – 9 a.m.)

Shred Day: We are partnering with Iron Mountain to provide all employees a free, safe and secure opportunity to shred personal confidential documents on-site. This includes any personal documents with confidential or identifying information like old mail, checks, receipts, tax reports, credit card statements, etc. Plastic, metal or other non-paper items will not be accepted. Click here for a printable flyer.

Shred Day Drive-Up Event

Saturday, Nov. 11 (8 a.m. – 12 p.m.)
6330 West Loop South, Bellaire, TX 77401

Click here to learn more. Need additional help? Contact the Compliance and Privacy Office at 832-824-2085 or compliance@texaschildrens.org.

November 2, 2020

Even at an organization as high performing as ours, it’s important that we remember to uphold compliance and ethical standards in everything we do. That’s why the celebration of Compliance and Ethics Week is so important. All week long, compliance officers across the organization will be available to answer questions about the work they do to ensure that we meet federal and state regulatory requirements.

“This week is so important to help raise awareness and to help promote a culture of compliance within the organization,” said Devona Williams, Director of Controls and Compliance at Texas Children’s Health Plan. “I think we do extremely well. However, we do have room for improvement in educating team members about what Compliance does, the importance of it and the potential consequences for non-compliance.”

Tessy Carpenter, Interim Director of Compliance & Privacy, reminds the organization that compliance is everyone’s responsibility at Texas Children’s. “It forms the foundation for the ethical environment we want to create and maintain, and supports our workforce members’ daily efforts to act with integrity.”

Reminders about compliance

Compliance and Ethics team members ensure that we meet federal and regulatory requirements. This week they remind us that:

  • We are all responsible for compliance.
  • Compliance professionals are not the police. They are our partners in protecting the organization.
  • Compliance does not make the rules. They ensure that the organization is compliant with applicable Federal and State regulatory requirements.

There are 7 elements to an effective Compliance program:

  • Designation of a compliance officer and compliance committee
  • Implementation of written policies, procedures and standards of conduct
  • Internal monitoring and auditing
  • Training and education
  • Enforcement and publicized disciplinary guidelines
  • Prompt response to offenses, with corrective action and reporting
  • Effective lines of communication
Texas Children’s Compliance Leadership

A big thank you to the men and women who lead our One Amazing Team in this area. We celebrate you – and your teams – this week.

Lance Lightfoot
Senior Vice President and General Counsel
TCH Compliance and Privacy Officer

Melissa Murrah
TCHP Chief Risk Officer
Vice President, Risk, Audit, Compliance, Privacy & Organizational Resilience

Tessy Carpenter
TCH Interim Director, Compliance & Privacy Office

Devona J. Williams
TCHP Director, Controls and Compliance

For more information about the Compliance and Privacy Office visit this Connect site. View the Texas Children’s code of ethical behavior for additional ethics guidance.

November 18, 2019

Maintaining the privacy and security of our patients’ and Health Plan members’ medical information is a key component of providing high quality care. Patients, Health Plan members, and their families must be able to trust that no one at Texas Children’s inappropriately accesses, discloses, or uses their protected health information (PHI). Having our patients’ and Health Plan members’ trust is an essential element of the care we provide and the relationship we develop with families.

As a Texas Children’s workforce member, you should only access medical records when it is part of your official, assigned work duties. Every “click” within our patient care systems is recorded. The Compliance and Privacy Office uses data analysis software to detect potential inappropriate access. When a workforce member appears to be “snooping,” the Compliance & Privacy Office coordinates with leadership and Human Resources to investigate and determine appropriate disciplinary action, up to and including termination. Three workforce members have been terminated this year for privacy violations.

Earlier this year, a child treated at Texas Children’s Hospital was the subject of multiple news stories. The Compliance and Privacy Office applied Epic’s Break-the-Glass tool to the patient’s record to deter inappropriate access. Despite these measures, two workforce members (who worked in areas in which the patient had no activity) “broke the glass” and accessed the patient’s record. Additionally, thirty-six workforce members searched the patient’s name in Epic but did not proceed past the Break-the Glass prompt into the medical record. This “snooping” was inappropriate and in violation of law and our policies. The two workforce members who accessed the patient’s record received disciplinary action, and the thirty-six individuals who searched the patient’s name received a warning from the Compliance and Privacy Office.

Your responsibility as a Texas Children’s workforce member is to:

  • Only access PHI when it is part of your assigned work responsibilities.
  • Do not access the records of your friends, family members, children, or yourself.
  • Do not access records out of curiosity.
  • Do not disclose PHI to unauthorized persons.
  • Do not share PHI on social media sites (Facebook, Instagram, Twitter, etc.).

Key Takeaway! Do not access any medical record unless it is necessary to do your job. Inappropriately accessing, using or disclosing PHI is a violation of federal and state law and Texas Children’s policy, and may result in disciplinary action, up to and including termination.

Questions? Contact the Compliance and Privacy Office by calling 832-824-2085 or emailing compliance@texaschildrens.org.

October 7, 2019

Social media is a great way to share glimpses of your life with family and friends. Engaging on social media is increasingly becoming part of our daily routines, so it’s more important than ever that everyone at Texas Children’s understands their responsibilities around social media use.

With that in mind, the Marketing/PR and Human Resources departments developed a short video about the appropriate use of social media. You can watch the video below and keep it front of mind whenever you use any social media platform.

Ultimately, every single person at Texas Children’s is responsible for how they use social media. Be sure you make informed, thoughtful decisions about what you choose to post online.

If you discover any unethical, illegal or questionable content on social media relating to Texas Children’s, please notify your immediate supervisor or call our confidential Compliance hotline at 1-866-478-9070.

 

December 12, 2017

The holidays are approaching, and with that comes the gift-giving season! In your role at Texas Children’s, you might have encountered situations where patients, Health Plan members, or vendors want to give you gifts to express their gratitude. And you’ve probably thought to yourself, can I accept the gift? Depending on your job, accepting a gift may interfere with your professional responsibilities, and could trigger violations of certain laws or ethical rules. So what is appropriate? Below are some FAQs to ensure you and your staff are appropriately handling gifts among Texas Children’s workforce members, patients, Health Plan members, and vendors.

Patients and Health Plan members

Can I accept cash or cash equivalents from a patient, Health Plan member, or their family?

No. Never accept cash or cash equivalents (including gift cards) from patients or Health Plan Members. Even a $5 gift card to Starbucks is not appropriate.

What other gifts can I not accept from a patient, Health Plan member, or their family?

It is not appropriate to accept high dollar value gifts such as expensive pens, jewelry, electronics, tickets to sporting events or concerts, or other extravagant items.

What can I accept from a patient, Health Plan member, or their family?

Gifts with nominal value are acceptable if they are infrequent and do not create an obligation on your part. Examples include food, flowers, and balloons. These types of gifts should be shared with your co-workers.

Can I give a gift to a patient, Health Plan Member, or their family?

Yes, you can give nominal gifts, valued under $15 per item, or $75 annually per patient or Health Plan member.

Never give cash, cash equivalents (including gift cards), or high dollar value gifts.

How can I politely decline a gift without offending a patient, Health Plan member, or their family?

  • Always express gratitude, even when you cannot accept the gift.
  • Clarify that Texas Children’s does not generally allow you to accept gifts.
  • Stress that you do not want other patients or Health Plan members to feel like they have to give gifts.
  • In the rare circumstances where return of a gift is not possible, the gift must be delivered to the Office of Philanthropy, who will use it for the benefit of patients and families.
Vendors

Can I accept cash or cash equivalents from a vendor?

No. Never accept cash or cash equivalents (including gift cards) from vendors.

What other gifts can I not accept from a vendors?

It is not appropriate to accept gifts from vendors that may influence or appear to influence their decision-making on behalf of Texas Children’s.

What can I accept from a vendor?

Gifts with nominal value are acceptable if they are infrequent, of nominal value and do not create an obligation on your part. Examples include food, flowers, and balloons. These types of gifts should be shared with your co-workers.

Unsolicited offers of entertainment or social events (e.g. attendance at a sporting or cultural event, participating in a sporting activity) as long as long as they are infrequent, do not improperly influence behavior, and will not influence any part of a decision making process.

Can I accept gifts from vendors that are involved in a bid/award process?

No. If a vendor is involved in a Request for Proposal, Request for Information, or Request for Quote, you may not accept any gift or meal, regardless of its value.

Colleagues

Can I give or accept a gift from a co-worker?

Yes, you can exchange gifts with your colleagues, as long as you paid for the gift yourself. You may not use Texas Children’s funds (e.g. eReimbursement, ProCard) for gifts for colleagues.

If you have a question about giving or receiving gifts, please contact Compliance and Privacy (ext. 4-2085 or compliance@texaschildrens.org).

October 31, 2017

At Texas Children’s, we are committed to leading tirelessly in maintaining an ethical workplace. Every day, we hold each other accountable to the highest standards of integrity and ethical behavior.

To recognize and promote the importance of integrity and ethics at Texas Children’s, we will be celebrating National Corporate Compliance and Ethics Week during the week of November 6 – 10.

During the week, the Compliance and Privacy Office will be hosting a series of awareness events throughout the organization. This is a wonderful opportunity to meet members of the Compliance and Privacy Office, learn more about what we do, play games and win prizes. For a complete schedule of events, click here.

Thank you for your continued support of our Compliance and Privacy programs. If you have any questions, please contact the Compliance and Privacy Office at ext. 4-2085 or compliance@texaschildrens.org.