Communicating with Research Subjects Remotely

Guidance for CUIMC on Applications That Can Be Used to Contact Research Participants

In these unique circumstances, rules are constantly evolving for the use of technology to assist providers and researchers in engaging with their patients and research subjects. Additional guidance on the feasibility of various technology applications is being provided by CUIMC IT to assist staff and faculty who have questions about what options are available.

All assistance requests for Google Voice, FaceTime, and WhatsApp should start with departmental IT staff, and then can be routed to 5HELP if it requires further examination.

Current HHS guidelines allow latitude to use technology to assist in patient communications during the current healthcare emergency. These guidelines are outlined at - https://www.hhs.gov/hipaa/for-professionals/special-topics/emergency-preparedness/notification-enforcement-discretion-telehealth/index.html

WhatsApp and FaceTime

WhatsApp and FaceTime are permitted during the current COVID-19 health emergency to contact research participants. Columbia encourages faculty to use those applications where Columbia has a Business Associate Agreement (BAA) but we have included support for FaceTime and WhatsApp as acceptable methods of communication from an iPhone/iPad device. Android devices may use WhatsApp as required for research participant communication. Responsibility for removal after we are back to normal operations will rest with the user.

Google Voice

Google Voice may also be used by researchers who wish to engage with participants. Researchers may work with CUIMC IT to setup Google Voice accounts.

Doximity Dialer

CUIMC IT also recommends the use of the Doximity Dialer application if research staff wishes to make the phone number used for contact with a research participant or family private.

Outpatient Telemedicine

For outpatient telemedicine (i.e. video visits), providers are strongly recommended to continue to use Epic platform. If a non-Epic platform is used to support necessary patient care, providers are encouraged to use HIPAA Compliant video communication products (e.g. Zoom for Healthcare). Other third party applications that are non-public facing (see below) are permissible under the State of Emergency, and if used, patients must be reminded about potential loss of privacy.

Non-public Facing Remote Communication Products

Researchers may follow similar guidelines in contacting research subjects, through the definition of a “non-public facing” remote communication product. A “non-public facing” remote communication product is one that, as a default, allows only the intended parties to participate in the communication.

Non-public facing remote communication products would include, for example, platforms such as Apple FaceTime, Facebook Messenger video chat, Google Hangouts video, WhatsApp video chat, Zoom, or Skype. Such products also would include commonly used texting applications such as Signal, Jabber, Facebook Messenger, Google Hangouts, Whatsapp, or iMessage. Typically, these platforms employ end-to-end encryption, which allows only an individual and the person with whom the individual is communicating to see what is transmitted. The platforms also support individual user accounts, logins, and passcodes to help limit access and verify participants. In addition, participants are able to assert some degree of control over particular capabilities, such as choosing to record or not record the communication or to mute or turn off the video or audio signal at any point. CUIMC recommends the use of Google Voice, FaceTime and WhatsApp for communication with research participants if required as part of an ongoing research study. Any use of these communication product recommendations is subject to IRB review and approval.

Public-facing Remote Communication Products

In contrast, public-facing products such as TikTok, Facebook Live, Twitch, or a chat room like Slack are not acceptable forms of remote communication for telehealth or research subject communication because they are designed to be open to the public or allow wide or indiscriminate access to the communication. For example, a provider that uses Facebook Live to stream a presentation made available to all its patients about the risks of COVID-19 would not be considered reasonably private provision of telehealth services. A provider that chooses to host such a public-facing presentation would not be covered by the Notification and should not identify patients or offer individualized patient advice in such a livestream.