Those interested in the potential for social media to help improve healthcare and the community’s health are expressing concerns about a preliminary consultation paper on social media policy from the Australian Health Practitioner Regulation Agency (AHPRA).

It seems that the document hit the Twittersphere ahead of a planned wider release for public consultation.

The document is causing a deal of consternation, especially among contributors to the Healthcare Communications and Social Media in Australia and New Zealand  or #hcsmanz Twitter chat group (as per some of the tweets at the bottom of this post).

It says the policy aims “to provide clarity for the public and health practitioners about the expected standards of social media use for registered health practitioners regulated under the National Law” and has been developed in response to requests from health practitioners and professional associations seeking guidance from the National Boards.

The document takes a fairly dim view of social media, focusing mainly on its potential to breach laws and guidelines relating to the advertising of regulated health services: “Some use of social media by registered health practitioners may contravene the code of conduct, the Advertising Guidelines and other relevant legislation.”

It says registered health practitioners “should be aware of the risks and implications of using social media”. It fails to acknowledge the potential benefits for service delivery and improvement, public health efforts, and for enabling greater public participation, whether in research, services or policy.

Croakey also wonders what the draft policy might mean for the ability of health professionals to engage in online activism – such as the recent excellent efforts of surgeon Dr Jill Tomlinson (as per the tweet below) and other doctors in contributing to the #destroythejoint social media campaign. This arose in response to an Alan Jones complaint about female leaders “destroying the joint”.  (An example of humour being the best medicine, perhaps…)

The AHPRA document states:

The definition of advertising under the Advertising Guidelines is broad. It includes use of social media such as posting an online message or group comment on a practitioner’s Facebook page or LinkedIn connection.

The National Law provisions on advertising apply to:

• practitioners registered under the National Law

• employers of practitioners and

• other persons who provide services through the agency of a registered health practitioner.

A person advertising a regulated health service may contravene the National Law even if they are not themselves a registered health practitioner. As a result, a person may be found to have ‘advertised’ a health service even though they did not intend to advertise or promote their health service.

A practitioner who contravenes the National Law, the code of conduct or the Advertising Guidelines may face disciplinary action that could affect their registration.

In summary, the document says:

When using social media, health practitioners should remember that the National Law, Advertising Guidelines and the code of conduct apply.

Registered health practitioners should only post information that is not in breach of these obligations by:

• not breaching professional obligations

• not breaching confidentiality and privacy obligations (such as discussing patients or posting pictures of procedures, case studies, patients or sensitive material)

• presenting information in an unbiased, evidence informed context and not making unsubstantiated claims and

• not using testimonials or purported testimonials in any capacity on any medium.


Croakey is keen to hear from readers about the policy – and will post a compilation of responses to help inform AHPRA’s consultation process.

Some specific questions to consider:

• What are the implications of the draft policy for current and future uses of social media by health professionals and services?

• What might be some of the unintended consequences of the policy?

• What do you think the policy should cover and recommend?

• What advice would you give AHPRA?  How can a balance be achieved that enables positive use of social media while stopping uses that are not in the public interest? Is there a need for a review of relevant legislation and guidelines?

• Are there any relevant policies, from Australia or from overseas, from the health sector or other sectors, that you would recommend to AHPRA?


Further reading

In the meantime, the following resources might help inform a wider debate about the use of social media for health:

• From the London School of Economics: Using Twitter in university research, teaching and impact activities: A guide for academics and researchers

• The US Centers for Disease Control and Prevention social media portal

• A recent presentation from the George Institute about the potential public health benefits of engaging with Twitter

• A US perspective on Using YouTube for patient education and information

• We need more health professionals online, says US doctor, because that’s where the people are

• A US presentation about best practices in social media (it’s not about marketing but about improving care)

• Webicina: a wealth of resources on social media and healthcare


A small sampling of the concerns being raised on Twitter…



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