Text Messaging and WIC

Reference: MOM Section 9.6: Electronic Communication Security (PDF)

Text messaging is NOT considered a secure form of communication. Although a texting platform may indicate they are HIPAA compliant, it is the Local Agency’s responsibility to ensure the participant’s data is kept private and to follow Local Agency IT and Legal requirements.

If the Local Agency is using a texting platform, the Local Agency MUST:

• Receive and document the participant’s permission to receive text messages (see Section 1.7: Data Privacy (PDF)).

• Ensure text messages are easy to understand and do not contain abbreviations.
• Delete text messages immediately after viewing.

If the Local Agency is using a texting platform, the Local Agency MUST NOT:

• Send private information via text message.
• Text a participant using a staff members personal cell phone.
• Save a participant’s name to personal or Local Agency issued phone contacts list.
• Use free versions of texting services.
• Use an iPhone, unless it is ensured that iMessages are turned off, as these are automatically saved to an iCloud account.
• Request that a participant send any of the following via text:
  • Personal Health Information.
  • Identifiable data such as social security or driver’s license numbers.
  • Photos or proofs for certifications with personal information.
• If a participant wants to submit personal information via text message the Local Agency MUST inform the participant that it is not considered a secure way to submit information and offer alternate ways to submit the information electronically.

Text message consent and documentation

Beginning Oct. 1, we are standardizing how agencies collect participant preferences for receiving text messages from the WIC Program, including a new State Use Question, Text Message Release Documentation, and a new form Exhibit 1C-1a: Consent for Communication (PDF). For more information, see the New Text Messaging Documentation (PDF) memo.

Suggested text communication usage

The following are suggested uses for text messaging:

• Scheduling appointments and appointment reminders that do not include names.
• Inviting participants to phone calls.
• Sending links to food or nutrition resources.