Chance to talk to AHPRA's CEO about the advertising guidelines

The latest news from the AHPRA advertising guidelines saga is that Martin Fletcher, AHPRA CEO, is taking to Twitter to explain the guidelines and answer any questions. 

The Twitter chat is using hashtag #ahpraqanda and is taking place on Friday 28 March at 12pm AEST.

Even if you're not very interested in the topic, it will be worth following to see how a real-time hashtag chat works, and how an organization uses Twitter for engagement and PR.

Totally hooked on Hootsuite

Up until the last six months or so, I was a frequent user of Twitter. I used it to send around information and make real time connections with all sorts of people. But over the months, I have stopped feeling the Twitter love, and become a Facebook recluse.

This has partly been because the tool I was using to manage my Twitter accounts was closed down. And the other main reason was that with three Twitter accounts - my own personal account, the Australian College of Midwives, and the Virtual International Day of the Midwife - I started to feel completely over-whelmed.

For a number of years I have heard about Hootsuite, which is a tool that allows you to manage all your social media accounts in one place. I had played with it about two years ago, but never really got it. But this weekend I decided I would give it another go.

Hootsuite is web-based, which means I can access my account anywhere as long as I have Internet access. It allows me to manage and monitor multiple social media accounts such as Twitter, Facebook, LinkedIn and so.  For the time being, I have chosen to use Hootsuite for managing my three Twitter accounts.


I have to say that after only a couple of hours I am totally hooked. I have set up all three accounts so I can see who I am following, who is talking about me and who is talking to me. This will make it so much easier to monitor conversations and to answer messages in a timely manner. This is turn will improve engagement, especially for the two professional accounts I manage.

The other thing I have done is set up several hashtags I follow on Twitter, including #VIDoM14 and #phdchat. It is so much easier to have them all in one space, and will make it especially easier to manage at times of intensive use, such as the weekly chats such as  #hcsmanz - a chat every Sunday evening about health care and social media.

A further feature that I may find very useful is the ability to schedule messages, or tweets. This will make it so much easier to plan what and when I am going to post.

Do you use Hootsuite? How do you use it? What other social media management tools would you recommend?

AHPRA provides guidance for the guidance on advertising, but still leave health professionals with concerns

Over the last week or so, there are been a lot of discussion, concern and complaints about the advertising guidelines released by the Australian Health Practitioner Agency (AHPRA) -  full story can be read here. So much so that an online campaign has got going, and health professionals' associations have been lobbying to have the guidelines revised.

On Tuesday,  AHPRA released FAQ that has gone some way to clarify the advertising guidelines. AHPRA states:

• There is a difference between advertising and unsolicited online comments;
• The advertising guidelines do not apply to unsolicited comments over which practitioners have no control; 
• Practitioners are not responsible for removing (or trying to remove) unsolicited testimonials on sites over which they have NO control.

Still unsure about positive comments
However, there is still no clear guidance in the FAQ about unsolicited comments in the health practitioners’ own space. The FAQ initially say “There is a clear difference between advertising – which requires an advertiser’s intent to promote a health service – and unsolicited online comment, which does not involve an advertiser’s intent to promote a health service.” The FAQ then go on to say “Practitioners are not responsible for removing (or trying to have removed) unsolicited testimonials published on a website or in social media over which they do NOT have control.” There is no mention of how practitioners should deal with unsolicited comments in websites or social media which they DO control.

Should we need guidance to read the Guidance?
At the beginning of the FAQ, AHPRA states “We will keep updating these FAQs to answer questions about emerging issues and guide practitioners about their regulatory responsibilities in relation to advertising.” Whilst it's great that AHPRA is willing to respond to practitioners’ questions as they emerge, I feel that the Guidelines should be easy to understand, consistent, and lacking contradictions in the first place. Then there would not be such a need to provide guidance on how to read the Guidance. I am also very concerned about the fluid nature of the FAQ. I feel it makes practitioners vulnerable and begs the question about how much reliance we can put on the changing information in the FAQ.

What is the legal impact of inconsistencies between Guidance and FAQ?
Finally, in view of the confusion and inconsistency between the Guidelines and FAQ I am left asking what would be held up in a court of law – the Guidelines, or the FAQ which contradict the Guidelines?

 Need for robust guidance
The #AHPRAaction campaign are asking for the complete removal of the section of the guidelines that talks about social media and testimonials. I am not sure I agree with the complete removal because I feel there needs to be guidance on the difference between testimonials and unsolicited comments. However, I would call upon AHPRA to incorporate the FAQ into the Guidelines. This will significantly strengthen the Guidelines and decrease risk to practitioners, especially in the face of vexatious reporting that I have already heard is happening in relation to practitioners’ use of social media.

I would also recommend that the Guidelines are reviewed again in one to two year’s time, instead of three years. The social media landscape changes very quickly and a shorter time frame for review is appropriate in this instance, especially as this is a relatively new area for regulatory consideration.

What do you think? Are the FAQ clear? How will the Guidelines impact on your practice?

Two sides to every gardening story

As far as I am concerned, one of the great mysteries of life is how everyone and anyone can grow the most wonderful vegetables in the most unusual pots and challenging locations but I can't!!! 

I know all about vertical gardening....

                                                                                                                   growing vegetables in pots...

making the most of a balcony...

But do you think I can manage anything similar?!  The answer is NO!

I lost track how much I spent this spring on pots, plants and compost, with the view of feeding Africa from the produce I would grow on the balcony of my flat in Canberra. 

This is all I managed....3 tomatoes...and 4 capsicum the size of gob stoppers!

Honestly...I give up!

Confusion for Australian health professionals about AHPRA advertising guidelines and social media

In the last couple of weeks the Australian Health Practitioner Regulation Agency (the body that regulates health professionals in Australia) has released its social media policy and advertising guidelines. They are generic documents and apply to all the health professions that AHPRA regulates, including midwives, nurses and doctors. The social media policy is broad and uncontroversial. But the advertising guidelines, in particular the advice regarding social media, has caused a good deal of confusion and consternation amongst health professionals.

What is the difference between a testimonial and unsolicited online comment?
The problem with the guidelines is the lack of clarity around the difference between a testimonial used for advertising the services of a health service or health professional, and an unsolicited online comment that is posted by a consumer in an online space, such as Facebook or review website.

It is illegal for health professionals in Australia to use solicited testimonials to advertise their services because of the potential to interfere with health consumers' ability to make informed choices about their care.

What the guidelines advise is that unsolicited appreciative comments or stories posted by health consumers in online spaces belonging to health professionals, such as Facebook, could be deemed as testimonials, and must be removed. Additionally, if these comments are posted in the consumers' own online spaces, health professionals must do all they 'reasonably' can to get the comments removed.

Does AHPRA understand how social media works?
Since the guidelines were published, there has been a lot of discussion about this apparent lack of understanding of how social media works. Social media gives health consumers a voice that they often do not have in the face-to-face setting. Online comments that are both appreciative and critical increase transparency in health care practice, and provide health professionals feedback that supports reflection. These comments and stories are the everyday way that people network and hold online conversations using social media, and generally are not used for advertising.

Is it right to censor health consumers?
One of the main concerns is that the guidelines appear to be an attempt to gag health consumers. The guidelines say that stories told by health consumers and patients could be construed as testimonials. This has huge implications for health professionals. For example, if a woman tells her birth story on her blog and talks about the excellent midwifery care that I provided, I would have to ask her to remove any reference to my clinical care. At best, it feels rude to do that, and could potentially impact on my relationship with that woman  - at worse, it feels like censorship.

This advice has implications that reach beyond the online environment.  For example, could health professionals be disciplined because of what consumers say about them in birth or death announcements? Would the nurse who was praised for her care of a terminally ill patient in a death announcement be taken to court?

How 'reasonable' is AHPRA being?
A further concern that health professionals have is the advice that they must make "reasonable" efforts to have comments and stories removed from online spaces that are not under their control. There is no discussion about what it deemed to be reasonable. Keeping in mind how far comments are shared, 'liked' and re-tweeted, the guidelines do not make it clear what is considered to be 'reasonable'  and how far health professionals have to go to get online content removed, or how they should track online content.

All for one, and one for all?
Criticism has ensued since the publication of these guidelines, especially from doctors. This led to what appeared to be back-tracking from the Medical Board last Friday, when Dr Joanna Flynn announced in a media statement that "there is a clear difference between advertising - which requires an intent to promote the health services - and unsolicited online comment over which practitioners do not usually have control", and that health professionals are not expected to monitor or control what is written about them in online spaces.

This statement was well received by doctors, but the rest of us continue to be unclear if the statement from the Medical Board applies across all the other national Boards ie was the Medical Board speaking on behalf of AHPRA? 

Another question is, what credibility does this media statement have compared to the guidelines?  In other words, if I am charged with breaching National Law, am I judged against the media statement, or the guidelines?  If this response to one doctor is anything to go by, the Medical Board spoke out of turn, and AHPRA does not intend to change the stance that it has taken in the guidelines.

Where does this leave us?
Until if or when the guidelines are amended, health professionals must use them as their basis for practice, and not base their actions on unsubstantiated media statements.

In the meantime, I would advise all health professionals to write to AHPRA asking that they amend the guidlines to clarify that:

• testimonials are solicited comments and stories used for the purpose of advertising;
• unsolicited comments and feedback from consumers in either health professionals' online space, or that of the consumer, are not considered to be testimonials;
• heath professionals are not expected to monitor online spaces, or ask consumers to remove content from consumers’ own space.

Disclaimer:  This blog post contain my own views and are not necessarily that of the Australian College of Midwives

Image: 'Does flickr need an eyetest (freedom test)?'
http://www.flickr.com/photos/60364452@N00/546901054