HIPAA-Compliant SMS Messaging for Healthcare

Healthcare SMS Compliance Framework

Healthcare organizations face dual compliance requirements: HIPAA regulations governing Protected Health Information (PHI) AND TCR/TCPA requirements for all commercial SMS messaging. MyTCRPlus provides integrated compliance infrastructure addressing both frameworks.

HIPAA Requirements

PHI Protection: No transmission of specific medical information via SMS without encryption
Patient Consent: Explicit written authorization for appointment reminders and health notifications
BAA Required: Business Associate Agreement with messaging platform provider
Audit Logs: Complete message delivery records for HIPAA compliance audits
Breach Notification: Procedures for unauthorized access or delivery failures

TCR/TCPA Requirements

10DLC Registration: Brand and campaign approval via The Campaign Registry
Use Case Selection: Healthcare use cases (appointment reminders, prescription alerts)
Sample Messages: Compliant templates demonstrating TCPA opt-out language
Trust Score: Healthcare providers typically score 60-75 baseline (+5 industry bonus)
Consent Records: Timestamp logs with patient authorization documentation

Critical Compliance Note

HIPAA does NOT prohibit SMS messaging for healthcare communications. However, PHI transmission requires patient consent and appropriate safeguards. Appointment reminders WITHOUT specific medical details (e.g., "Your appointment is tomorrow at 2pm") are generally HIPAA-compliant. Lab results, diagnoses, or treatment details require secure portal access, not direct SMS content.

Healthcare-Specific TCR Use Cases

Appointment Reminders

TCR Use Case: Customer Care

Automated notifications for upcoming appointments, with date/time/location details. No specific medical information included.

Compliance Requirements:

✓ Patient consent at registration/intake
✓ Clear opt-out language in every message
✓ No PHI in message body (use secure portal links)
✓ 24-48 hour advance reminder timing

Prescription Alerts

TCR Use Case: Delivery Updates

Refill reminders, ready-for-pickup notifications, prescription transfer confirmations. Generic medication references only.

Compliance Requirements:

✓ Pharmacy consent during prescription intake
✓ No specific drug names in SMS (use "your prescription")
✓ Pharmacy identification in message
✓ Secure portal link for prescription details

Lab Results Availability

TCR Use Case: Account Notifications

Notification that test results are available. NO results content in SMS — portal access only.

Compliance Requirements:

✓ Patient authorization for result notifications
✓ Generic message: "Results available" only
✓ Secure patient portal link required
✓ Time-sensitive delivery (results released within hours)

Telehealth Coordination

TCR Use Case: Customer Care

Video consultation links, pre-visit instructions, post-visit care summaries (via portal link).

Compliance Requirements:

✓ Telehealth consent includes SMS notifications
✓ Secure video link (not unencrypted join codes)
✓ Provider identification in message
✓ Alternative contact method for opt-outs

Billing & Payment

TCR Use Case: Account Notifications

Payment reminders, balance notifications, insurance claim updates. No specific procedure codes.

Compliance Requirements:

✓ Financial communication consent separate from care
✓ Amount due without procedure linkage
✓ Secure payment portal access
✓ TCPA compliance for billing communications

Health & Wellness

TCR Use Case: Mixed Marketing

Preventive care reminders, flu shot campaigns, chronic disease management tips. Educational content.

Compliance Requirements:

✓ Opt-in consent for wellness communications
✓ Generic health tips (no patient-specific recommendations)
✓ Marketing use case if promotional
✓ Clear opt-out in every message

HIPAA + TCR Compliant Message Templates

Appointment Reminder Template

COMPLIANT

Hi [Patient First Name], this is [Practice Name] confirming your appointment on [Date] at [Time]. Our office is located at [Address]. Reply CONFIRM or call us at [Phone] with questions. Reply STOP to opt out.

Compliance Score: 95/100

Character Count: 147 (1 segment)

Why Compliant:

✓ Clear business identification
✓ No PHI (specific medical details)
✓ Explicit opt-out language
✓ Contact method for questions

Prescription Ready Template

COMPLIANT

[Pharmacy Name]: Your prescription is ready for pickup at [Location]. Hours: [Hours]. Questions? Call [Phone]. Visit [URL] for details. Reply STOP to opt out of these alerts.

Compliance Score: 92/100

Character Count: 152 (1 segment)

Why Compliant:

✓ No medication names (PHI protection)
✓ Pharmacy identification clear
✓ Secure portal link for details
✓ Delivery notification use case

Lab Results Notification

COMPLIANT

[Practice Name]: Your test results are now available. Log in to your patient portal at [URL] to view them securely. Questions? Call [Phone]. Text STOP to unsubscribe.

Compliance Score: 98/100

Character Count: 149 (1 segment)

Why Compliant:

✓ Zero PHI in message body
✓ Secure portal access required
✓ Generic "test results" language
✓ Best practice for HIPAA compliance

❌ NON-COMPLIANT Example

VIOLATION

Hi John! Your blood sugar test came back at 165 mg/dL. Dr. Smith wants to adjust your diabetes medication. Call us to discuss your treatment plan.

HIPAA Violations:

✗ Specific test results in message (PHI)
✗ Medical diagnosis referenced (diabetes)
✗ Treatment plan discussed in unsecured channel
✗ Provider name linked to patient condition

TCPA Violations:

✗ No opt-out language
✗ No business identification

Penalty Exposure: Up to $25,000 per violation (HIPAA) + $1,500 per message (TCPA)

Common TCR Rejection Issues for Healthcare

Sample Messages Include PHI

Submitted message templates contain specific medical information, test results, diagnoses, or treatment details. Even genericized patient names with medical context create PHI exposure.

Fix: Rewrite samples using generic references only. "Your appointment" not "your cardiology follow-up." "Your prescription" not "your insulin refill." "Results available" not any specific values.

Missing BAA Documentation

Healthcare organizations require Business Associate Agreement with messaging platform. TCR reviewers may request BAA confirmation during vetting process.

Fix: Execute BAA with your messaging service provider BEFORE TCR registration. Upload proof if requested. MyTCRPlus partners maintain current BAA documentation.

Consent Language Unclear

Sample messages don't clarify patient consent mechanism or opt-out process. TCR requires explicit demonstration of TCPA compliance for healthcare communications.

Fix: Include opt-out language in EVERY sample message. Reference consent timing: "You opted in to appointment reminders at registration." Provide contact alternative for opt-outs.

Wrong Use Case Selection

Healthcare wellness programs registered as "Account Notifications" when content is promotional. Billing reminders classified incorrectly as "Customer Care."

Fix: Use Case Selector tool determines proper classification. Appointment reminders = Customer Care. Wellness tips with promotional intent = Mixed Marketing. Billing = Account Notifications.

Business Associate Agreement (BAA) Requirements

HIPAA mandates Business Associate Agreements between covered entities (healthcare providers) and third-party vendors handling Protected Health Information. SMS messaging platforms qualify as business associates requiring BAA execution.

BAA Must Include:

Permitted uses and disclosures of PHI
Security safeguards implementation
Breach notification procedures
Subcontractor compliance requirements
Termination and data return provisions

Healthcare Provider Responsibilities:

Obtain patient consent for SMS communications
Verify BAA execution before PHI transmission
Limit SMS content to non-PHI when possible
Maintain consent and delivery audit logs
Monitor for unauthorized access or breaches

MyTCRPlus BAA Support

MyTCRPlus partners with HIPAA-compliant messaging infrastructure providers maintaining current Business Associate Agreements. Our platform facilitates BAA documentation and compliance verification as part of healthcare client onboarding.

Request BAA Documentation →

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