Media Policy

In order to establish a standard policy for the release of information and to maintain a centralized channel of community with the local media, Willis-Knighton Health System has established the following guidelines. Willis-Knighton recognizes the valuable role media plays in a free society. Our goal is to provide information that is accurate, official and consistent. 

Our policy includes cooperation with representatives of the news media in legitimate news-gathering activities, being mindful of legal concerns and patient confidentiality issues. Paramount in all of our activities with the media is the health and well-being of our patients and their families; this must take precedence over our obligations to the media. The media policy is designed to protect the confidentiality of patients in compliance with privacy standards for healthcare information as dictated by The Health Insurance Portability and Accountability Act of 1996 (HIPAA) as amended. 

Under HIPAA guidelines, each of the health system’s hospitals will maintain a directory of patients who have given permission for information to be released regarding their presence in the hospital. A one-word condition report of each of these patients will be available when requested by the media. 

According to hospital policy, the Department of Marketing and Public Relations has the responsibility and authority to manage communications with the media. The full cooperation of all hospital departments and personnel is critical to achieving our communications goals. 

PERSONS AUTHORIZED TO RELEASE INFORMATION

To meet the health system’s communication goals and to assure accuracy and consistency of messages, the following persons (listed in order they should be contacted if the media reaches areas other than Marketing and Public Relations) are authorized to release information to the news media: 

INFORMATION ABOUT PATIENTS

• Manager, Public Relations or designated member of Marketing and Public Relations staff 
  Available around the clock by pager-See Meditech "Marketing Information" for numbers.

OTHER INFORMATION

• Manager, Public Relations or Director of Marketing and Public Relations or Designee
  Contact at home/by pager when not in the hospital.
  One of these staffers is available around-the-clock. Pager numbers for media relations are listed in the on-call list and on Meditech "Marketing Information."
• Administrative Person on-call – by facility
  Release of information by other than a person designated above is strictly prohibited.

RELEASE OF INFORMATION

All requests from the media for information regarding patients during should be directed to the Department of Marketing and Public Relations. Pagers numbers are found in the “on call” list and on Meditech "Marketing Information."

Condition and Location of Patients: What May Be Released and To Whom

• Inquiries must contain the patient's name--unless the inquiry comes from clergy.
  Information about the condition and location of an inpatient, outpatient or emergency department patient may be released only if the inquiry specifically contains the patient's name and if the patient has not opted out of the hospital directory. No information is to be given if a request does not include a specific patient's name. 
  
  Inquiries from the clergy are an exception. HIPAA privacy regulations expressly permit hospitals to release the patient's name, location in the hospital, general condition and religion to clergy members, so long as the patient has not told you not to release the information. Clergy do not need to ask for the individual by name. (Hospitals are not required to ask about patients' religious affiliations and patients are not required to supply that information.)
• The hospital may release the patient's one-word condition and location without obtaining prior patient authorization--as long as the patient has not opted out of the hospital directory (asking that it not be released.) 
  
  
• Condition
  The following one-word conditions are the only condition reports approved for release:

UNDETERMINED - Patient awaiting physician and/or assessment.

GOOD - Vital signs are stable and within normal limits. Patient is conscious and comfortable. Indicators are excellent.

FAIR - Vital signs are stable and within normal limits. Patient is conscious but may be uncomfortable. Indicators are favorable.

SERIOUS. Vital signs may be unstable and not within normal limits. Patient is acutely ill. Indicators are questionable.

CRITICAL - Vital signs are unstable and not within normal limits. Patients may be unconscious. Indicators are unfavorable.

Note: The term "stable" should not be used as a condition or in combination with other conditions. 

DEATH - The death of a patient may be reported to the authorities by the hospital if the decedent’s next-of-kin have been notified and if the patient’s legal representative gives authorization. Information about the cause of death must come from the patient's physician, not the hospital’s representative. The hospital cannot share information with the media about cause of death, even sudden, violent or accidental deaths that may have been reported by law enforcement officials. 

It is the responsibility of the authorized Marketing representative to confirm with the House Supervisor or Patient Care Coordinator that the patient’s next-of-kin has been notified before releasing information that a patient has died.

TREATED AND RELEASED – Patient received treatment but was not admitted.

TREATED AND TRANSFERRED – Patient received treatment; was transferred to a different facility. (Although we may disclose that a patient was treated and released, we cannot release information regarding the date of release or where the patient went upon release unless authorized to do so by the patient.)

• Location
  To safeguard the privacy of patients, the disclosure of a patient's location may not be made to the media without patient permission. 
• When a Patient Cannot Express a Preference
  In some cases, patients will not have had the opportunity to state a preference about having their information released. In this case, condition and location information should only be released if, in the hospital's professional judgment, releasing such information would be in the patient's best interest. When the patient recovers sufficiently, the hospital must ask about information preferences. 
• In Disaster Situations
  Information may be released to other hospitals, healthcare facilities and relief agencies in situations where multiple facilities are receiving patients from one disaster.
  
  General information may also be released to help dispel public anxiety. For example, we may report, "our facility is treating four individuals as a result of the explosion." We may also state the number of patients brought to our facility by gender or by age.

To safeguard the privacy of patients, the disclosure of a patient's location may not be made to the media without patient permission. 

MATTERS OF PUBLIC RECORD/PUBLIC FIGURES

Matters of public record refer to situations that are reportable by law to public authorities, such as law enforcement agencies, the coroner or public health officers. While laws and/or regulations require healthcare facilities to report a variety of information to public authorities, it is not the responsibility of facilities to provide that information in response to calls or other inquiries from the media or other parties, including law enforcement officials. Instead, calls regarding matters of public record should be directed to the appropriate public authority.

Patients Involved in Matters of Public Record 

Patients who are involved in matters of public record have the same privacy rights as all other patients as far as the hospital is concerned. If a call is received regarding a patient involved in a matter of public record, the media must know the patient's name at the time of the call. The hospital will release the appropriate one-word condition, provided the patient has not opted out of the hospital directory.

Celebrities/Public Figures 

Celebrities, public figures and public officials have the same privacy rights as all other patients as far as the hospital is concerned. If a call is received regarding a celebrity, public figure or public official, information may be released only with the permission of the patient or legal authority. It must follow the one-word condition format unless the patient wishes to have other information released.

INFORMATION THAT CANNOT BE RELEASED

Patients may "opt out" of providing information to anyone.
Patients are informed when admitted as to information that will be included in the hospital directory. The patient may state that he or she does not want any information released, including confirmation of his/her presence in the facility.

Information may not be released if it could embarrass or endanger patients.
Absolutely no information--even a confirmation of a patient's being at a facility-- may be released in the case of patients being treated for alcohol or substance abuse. If knowledge of a patient's location could potentially endanger the patient (i.e. abusive partner, stalker, etc.), no information of any kind may be given out, including confirmation of the patient's presence at a Willis-Knighton facility.

Circumstances of Accident, Incident or Injury
No information may be given out regarding the circumstances of accident, incident or injury. 

Prognosis
Statements about prospects for recovery or likelihood of death may not be given.

Drugs or Alcohol-Intoxication 
No statement should be made regarding state of intoxication or lack thereof, or that an accident involved or did not involve alcohol or drugs.

AIDS
The hospital will not release or confirm any information regarding an AIDS victim. Requests for statistics on AIDS should go to appropriate agencies.

Name of Physician The name of the emergency physician handling a case should not be released without the permission of the physician.

MEDIA ON CAMPUS

In order to maintain privacy and proper conditions for patient care and to control access to patient care areas as well as sensitive departments, all interviews, photographs, television and news-gathering requests must be approved in advance through the Department of Marketing and Public Relations. The Department of Marketing and Public Relations will notify the following departments regarding media on campus: Administration, Security and, when media will be on nursing units, Nursing Administration.

The taking of photos, video or filming within the hospital, on a Willis-Knighton campus or in a Willis-Knighton property is strictly prohibited unless the manager of public relations or a person designated by the manager of public relations is present. Media representatives should be met in the lobby and accompanied to the approved area by the PR manager or designee. Following the visit, the PR manager or designee should escort the media to their vehicle or to the parking area.

Any employee who sees an unattended media representative in Willis-Knighton facilities should approach the representative, greet the person warmly, and verify that a contact has been made with the Department of Marketing & Public Relations. The employee should emphasize that patient privacy and hospital policy require that media representatives be accompanied by marketing department representatives. Security may be called to wait with the media representative until Marketing arrives or is contacted. 

REQUESTS FROM THE MEDIA - PATIENT
(Interviews, photographs, television and news-gathering requests)

When a media representative requests the privilege of interviewing, photographing or filming a patient, such permission may be granted by the hospital if, and only if all of the following conditions are met:

• The patient’s medical condition will not be jeopardized in any way as a result.
• The patient’s medical care will not be interrupted.
• The patient (or in the case of a minor, the parents or guardian) grants written permission that he or she is willing to be interviewed and/or recorded and/or photographed and/or filmed AND signs a “Interview/Photo/Video Release Form.”
• The physician in charge agrees.

In every instance involving filming, recording or photographing or interviews all parties to be filmed, recorded, photographed or interviewed must sign an “Interview/Photo/Video Release" form. This should be done in advance of the action and applies to employees and physicians as well as patients and their families.

All “Interview/Photo/Video Release” forms except patient release forms will be stored in the Department of Marketing and Public Relations. Patient release forms must be placed in the patient’s chart.

REQUESTS FROM THE MEDIA – NON-PATIENT
(Interviews, photographs, television and news-gathering requests)

Requests or inquiries regarding non-patient information – which may include questions regarding finances, policies, services, employees, etc. – should be referred to the Manager of Public Relations Monday through Friday, 8 a.m. to 4:30 p.m. Urgent after-hours requests for this information should be forwarded to the administrative on-call person. The administrative on-call person may choose to contact the Manager of Public Relations (or designated Department of Marketing and Public Relations staff member) by pager for assistance in responding to urgent after-hours requests. Pagers numbers are found in the “on call” list on Meditech. The Manager of Public Relations should be notified of these contacts for follow-up purposes and to include in a log of all media contacts maintained by the department.

When a media representative requests the privilege of interviewing, photographing or filming an employee in the course of their duty, such permission may be granted by the hospital if, and only if, all of the following conditions are met:

• The employee grants permission that he or she is willing to be interviewed and/or recorded and/or photographed and/or filmed AND signs an “Interview/Photo/Video Release Form.”
• The employee’s department head/supervisor agrees.
• The Director of Human Resources agrees.

In every instance involving filming, recording or photographing, all parties (patients, family, employees) to be filmed, recorded or photographed must sign an “Interview/Photo Video Release" form. This should be done in advance of the action and applies to employees and physicians as well as patients and their families.

All completed “Interview/Photo/Video Release" forms except patient release forms will be stored in the Department of Marketing and Public Relations. Patient release forms must be placed in the patient’s chart.

REQUESTS TO THE MEDIA
(Interviews, Photographs, Television and News-Gathering Requests)

It is the responsibility of the Department of Marketing and Public Relations to prepare news releases, schedule photography and secure coverage for the health system and its personnel acting in their professional capacity.

Any department/employee seeking coverage should contact the Department of Marketing and Public Relations, with the approval of the appropriate department head.

In order to maintain continuity, consistency and accuracy of messages to the media, requests for media coverage of health system events and any activities that take place on health system property should be made through the Department of Marketing and Public Relations. This also applies to creation of news releases about hospital personnel regarding their professional duties and affiliation with the health system.

Any department/employee seeking coverage should contact the Department of Marketing and Public Relations with the approval of the appropriate department head. This contact requirement with Marketing and Public Relations does not include, nor is it intended to cover, media-gathering activities of independent or network physicians (or those acting in their behalf) whose offices are located in Willis-Knighton-owned buildings; however, these physicians are expected to comply with Willis-Knighton’s media policy.

INTERVIEWS WITH NETWORK PHYSICIANS IN THEIR OFFICES

Network physicians may choose to address the media in their offices without contacting the Department of Marketing and Public Relations or securing a representative to be present for the interview. In this instance, the physician assumes responsibility for complying with all media policy guidelines in this document and assuring that only information regarding the practice is discussed. 

In addition, the physician or his/her designee must:

1. notify security and administration that media is expected at a specific time/date
2. secure release forms on any patient, employee or physician who participates in an interview or photograph (even those who are identifiable in background shots),
3. send completed releases to marketing to be filed, or, in the case of a patient admitted at the time of the interview or photograph, assure that the release is added to the patient’s chart
4. prepare appropriate supplementary media materials for distribution to the media when required
5. meet the media in the lobby/front of a WK building and escort him or her to the physician’s office or conference area. The media representative must also be escorted to the door or vehicle at the termination of the interview or photography.
6. assure that no photography or interviews are done outside the scope of the original activity or topic scheduled by the physician (this includes photography of the outside of buildings)
7. provide media with written back-up information or visuals as needed
8. assure accuracy of all information given the media (including grammar and spelling) and conform to health system style sheet for accurate terminology regarding facilities, services, programs, etc.
9. be aware of and conform to the health system’s overall Media Policy.

Marketing & Public Relations is available to all network physicians for media relations consultation and support if they choose to take advantage of this service.

INTERVIEWS/PHOTOGRAPHS WITH PHYSICIANS IN COMMON AREAS

Interviews or photographs with any physicians that take place outside their offices in common areas, hospital departments, or patient care areas of Willis-Knighton buildings must be arranged in advance with the Department of Marketing and Public Relations.

CONFIDENTIALITY POLICY REGARDING MEDICAL RECORDS

The medical record is the property of Willis-Knighton Health System and shall be maintained to serve the patient, the healthcare providers and the institution in accordance with legal, accrediting and regulatory agency requirements. The information contained in the medical record pertains to the patient, and the patient legally is entitled to the protected right of information. All patient care information shall be regarded as confidential and available only to the authorized users. All requests for health records shall be directed to the Health Information Management (Medical Records) Department

LITIGATION

No statements shall be made regarding legal actions unless coordinated with and approved by hospital counsel.

COURTESY

Members of the media are to be treated by all hospital employees with the same courtesy and respect shown to our patients, their families and all others who come in contact with this institution.

Approved/Adopted January 18, 2002
Revised April 1, 2003
Reviewed April, 2004
Reviewed April, 2005
Revised April, 2006
Reviewed April, 2007

Note: In the event of a city-wide disaster, the standard HEICS protocol will be followed. 

Note: Public relations practitioners at Willis-Knighton Health System subscribe to the code of ethics for the professional practice of public relations of the Public Relations Society of America. The code may be viewed at www.prsa.org.