Navigating The New A2P 10DLC Regulations in Healthcare: A Guide for Healthcare Text Messaging

The following is a guest article by Dr. Lea McMahon LPC, EdD, Chief Clinic Officer at Symetria Recovery

Even in the sensitive healthcare industry, most patients prefer to communicate with their providers via text message instead of email, calls, or app messages.

New A2P 10DLC regulations require all businesses to register both their company and their specific text messages.

Quick note: A2P stands for Application-to-Person and essentially applies to all text messages that aren’t sent directly from a phone.

Starting September 1, 2023, A2P text messages that were not approved through this new process were blocked. For healthcare providers, that means patients aren’t getting critical appointment reminders and confirmation text, as well as billing, test result links, patient satisfaction surveys, prescription confirmations, etc. Even if a patient texted you first, you will not be able to respond until approved.

For companies looking to restart their text messages or those interested in adding text message communication options for their patients, the A2P 10DLC registration process has two parts:

  1. Brand Registration: Businesses need to clearly identify themselves to carrier networks. The process is straightforward, though requires a W-9 form.
  2. Campaign Registration: Businesses must give examples of the messages they’re sending, as well as show proof patients opted-in to receive text messages from your practice.

The process requires a small cost and initially estimated a 15 business days (3 weeks) approval turnaround. But, currently, the process is taking more than a month.  

And, not all registrations are getting approved. The most common denial reason is a noncompliant opt-in process.

Healthcare providers tend to be more focused on compliance than other industries but still may need to make some changes when it comes to text message opt-in.  

If a patient agrees to be texted on a recorded phone conversation or if the patient inbound texts your number first, the campaign registration should get approved. However, you should be gathering written consent upon intake as part of your standard paperwork or tablet patient registration. If the phone number was collected on a website or on intake paperwork, here are a few tips:

  • Ensure the text opt-in box is unchecked by default, requiring the patient to proactively check the box
  • Describe clearly what kind or frequency of text messages patients can expect
  • Include a disclaimer about the message and data rates and options opt-out
  • Give the call opt-in a separate checkbox from the text opt-in

Here’s an example of opt-in form messaging that would get approved:

By clicking this box, you provide express written consent to contact you via SMS no more than 2-4 times per month. Standard messaging and data rates apply. Text STOP to opt-out at any time.

A link to your privacy policy and terms of use pages would be nice to add here too. 

Most healthcare businesses send less than 6,000 messages a day and can register one “Low Volume Standard” campaign. For larger providers, each campaign needs to be registered separately (ie. marketing vs. customer care – including appointment confirmations).

The approval process is managed by The Campaign Registry (TCR). TCR works directly with major mobile operators like Verizon and T-Mobile to dictate which text messages can go through and which they should be blocked.

In most cases, you will submit the registration through the tool you are using (ie. the EMR, call center solution, etc). Some tools make the process easier than others.

Ultimately, most patients want to communicate through text messaging. It’s worth sorting through the compliance to give patients the communication they prefer. And, it might just give your healthcare business a leg up over competitors that don’t make the effort.

About Dr. Lea McMahon

With over 20 years of clinical experience, Dr. Lea McMahon LPC, EdD is a Licensed Professional Counselor and a recognized leader in human psychology and addiction science. She is an adjunct professor of psychology at Columbia College and Chief Clinical Officer at Symetria Recovery an outpatient drug rehab, methadone, and Suboxone clinic with locations across Illinois and Texas. Read more from Dr. McMahon on Symetria’s Ask Our Doctors addiction treatment blog.

   

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