Confidentiality, Privacy and Security

Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

  • 1.  Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 07-12-2019 09:33
    Hi, Everyone.  In our organization we have had two requests by staff members to have Alexa available in clinical areas - one in a waiting room (clinic) and one in a multipurpose room (nursing home).  I did a lot of research and there are some cool trials going on in healthcare facilities using virtual assistants.  However, based on my research, I am not sure virtual assistants are ready for "prime-time" in patient care areas in clinics or hospitals.

    Next that took me to Nursing Homes.  We have a 30-bed nursing home attached to the hospital.   There of course are shared areas, but each resident had his or her own room.   Nursing homes operate under different regulations but are still HIPAA covered entities.  With that sad, the resident's room is their "home," and I believe that the can control their homes and what devices they have in their homes.  We have residents with cell phones, computers, tablets, etc.  However, no one has asked for a virtual assistant yet - but I anticipate that is coming.

    When doing the research, I was struck by how many advantages a virtual assistant can bring to an elderly individual.  I do not think we would want to be a barrier to our residents have this tool available in their individual rooms.

    Anyone else have any thoughts or want to discuss further?   Thank you.

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    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
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  • 2.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 07-12-2019 11:05
    Hi Nancy,

    I was just hearing about Pharma using AI to answer questions about health, so I have to agree this is becoming popular, fast.

    My my understanding of Amazon Alexa and Google Home is that you need to have a personal account tied to this. My main concern would be how to set this up so it can't share PII and is generic.

    If if you're concerned about the listening functionality, there's a lot out there about how this works.

    My take- bolster your Operational Procedures to include the safe use of it. It will be hard to restrict the functionality from a technology perspective, but if you can exhibit control and checks operationally, it can make up for a lack in other areas.

    Alexa (not the Amazon one)

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    Alexandra Richards
    It Project Manager- Clinical Applications
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  • 3.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 07-13-2019 07:39
    There has already been a lot of discussion about digital technologies in the Nursing home sector.  We don't advertise that Residents can have Alexa but we allow them if wanted.  You have to check your state regs because Maryland is a two party communication state with regards to recording so we place a sign on the outside of the door frames letting all know that those Residents have an echo device in their room (home).  So far, it has worked well and I feel there is value in these devices.  We also have the POA sign a form that the facility is not responsible for any breakage or if the recording goes viral.

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    Barbara Naimark
    Medical Record Coordinator/Compliance Official
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  • 4.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 07-15-2019 09:30
    Barbara, Thank you.  What good advice.  I am going to add the posting of signage to my brief.

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    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
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  • 5.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 22 days ago
    Thank you for sharing the above information.  We recently had a family of our nursing home ask if they can put a "baby" camera in the room of the resident.  Always interesting.


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    Kimberle Johnson
    [Director HIM/Privacy and Compliance Officer]
    Campbell County Health
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  • 6.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 19 days ago
    Here is what I came up with:


     

    Understanding the Use of Alexa/Virtual Assistants in Healthcare Facilities

     

     

    Requested By:   DCMC SNF Leadership

     

    Issue Description:   

     

    On two occasions clinical staff members have asked about the use of Alexa in patient care areas of Door County Medical Center (DCMC) and the Skilled Nursing Facility (SNF).  This review explores the risks and benefits of the use of Alexa and/or other virtual assistants in DCMC facilities.

     

     

    Background:

     

    Alexa is a virtual assistant developed by Amazon.  It is capable of voice interaction, music playback, making to-do lists, setting alarms, streaming podcasts, playing audiobooks, and providing weather, traffic, sports, and other real-time information, such as news.  Alexa can also control several smart devices using itself as a home automation system. Users are able to extend the Alexa capabilities by installing "skills" (additional functionality developed by third-party vendors, in other settings more commonly called apps such as weather programs and audio features).  This guidance applies to Alexa and other virtual assistants provided by Google, Apple, etc.

     

    Amazon is moving into healthcare. Following a trial of using virtual assistants in patients' rooms at Cedars-Sinai, the company this morning announced an invite-only program allowing select developers to create and launch HIPAA-compliant healthcare skills for Alexa. The skills allow consumers to ask the virtual assistant for help with things like booking an appointment, accessing hospital post-discharge instructions, checking on the status of a prescription delivery and more.   Los Angeles medical center Cedars-Sinai is piloting a program that places Amazon Echos in more than 100 patient rooms. The smart speakers use Aviva, a voice assistant platform for healthcare, and is intended to help patients communicate with their caregivers. Letting patients use Alexa to perform basic tasks like changing TV channels also frees up nurses to perform medical care.   After a patient tells Alexa what they need, Aiva routes it to the right person's mobile phone. For example, if someone needs medicine, their request goes to a registered nurse. If a response takes too long, Aiva reroutes the request "up the chain of command." Voice assistants are currently being tested in several capacities in healthcare. For example, virtual assistants in Boston's Children's intensive care unit let nurses ask for administrative information, like who is the charge nurse on duty or how many beds are available in a ward. Boston Children's also piloted voice-enabled versions of the checklist used to validate organs before transplant, with prompts to help reduce error. KidsMD, a program powered by Alexa, is meant to be used by parents at home to help them decide if their kids need to see a doctor.

     

    Limitations of Virtual Assistants

     

    • Safeguarding the privacy and security of patient health information as well as other confidential information.   Currently virtual assistants cannot ensure patient privacy and are not HIPAA- compliant.
    • Device controls to only accept commands from authorized individuals.
    • Requirement for vendor HIPAA-compliant business associate agreement accepting risk.
    • Need for clear and concise voice commands which can be compromised in areas where there is an abundance of noise.
    • Logistics - Wi-Fi access.
    • Infection Control – maintaining clean equipment.
    • Security – maintaining devices in locations that are safe and secure.

     

     

     

     

    Nursing Home Residents:   The use of Alexa or another virtual assistant for a nursing home resident raises additional questions as the nursing home is the individual's "home" and residents have different rights regarding their home.   Virtual assistants for the elderly provide benefits that may outweigh any potential privacy risks.  Benefits may include:

     

    • Checking on date and time
    • Weather reports
    • News reports
    • Medication reminders
    • Listening to audio books – especially for visually impaired
    • Playing music
    • Alerting loved ones or others of falls or other emergencies
    • Controlling other devices (cell phones, tablets, computers, TVs, etc.).
    • Interact with games and tools to keep mind sharp

     

     

    As the virtual assistant may be actively recording interactions it is strongly recommend as a courtesy to others that signage be placed outside the room indicating that a virtual assistant is in place.  Language for the sign should state:

     

    "Virtual Assistant Present in Room; Interactions May be Recorded"

     

    Wisconsin recording law stipulates that it is a one-party consent state. In Wisconsin, it is a criminal offense to use any device to record or share use communications, whether they are wire, oral or electronic, without the consent of at least one person taking part in the communication. This means that in Wisconsin, you are legally allowed to record a conversation if you are a contributor, or with prior consent from one of the involved parties, barring any criminal intentions. Wis. Stat. Ann. @ 968.31

     

     

     

    Compliance – Regulatory Influences: 

     

    Wisconsin Law

    • 146.81-83 – Confidential of Health Records
    • WI @50.09 – Rights of Residents
    • DHS 132.31 – Rights of Residents

     

    Federal Law:

    • 42 CFR Part 483.10 – Resident Rights
    • 45 CFR Parts 160 and 164 – HIPAA Privacy and Security Rules

     

     

    Conclusion/Recommendations

     

    Hospital/Clinic Use:   Without solid documentation (e.g., contract, business associate agreement) of HIPAA compliance, the use of a virtual assistant for clinical operations or in clinical areas at this time is not feasible.  However, with continued advances in this technology, the feasibility of virtual assistants should be reviewed periodically.

     

    Nursing Home Resident Personal Use:   DCMC SNF provides individual rooms for residents as their personal homes.  Rooms are set up with WIFI and rooms are maintained and equipped at the resident's or his or her representative's design.   If a resident should desire that a personally-owned virtual assistant be utilized in his or her room, DCMC SNF should make every effort to reasonably accommodate this use contingent on the Organization's network/bandwith resources.

     

    Reviewed and Supported By:

     

    Communicated To:

     

     

    Prepared By:

                Nancy Davis, Director of Compliance & Safety

               



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    Nancy Davis, MS, RHIA, CHPS
    Director of Compliance & Safety
    Door County Medical Center
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  • 7.  RE: Alexa/Virtual Assistants in Hospital/Clinic/Nursing Home

    Posted 18 days ago
    I think Nancy hit the nail on the head.  For me in Nursing Homes, we don't advertise but if someone wants to put it in their "home" we allow them to do it.  We have a policy and we put a signature sign on the outside door frame letting people know they have an echo device in Resident's room.