Phreesia third-party content policy
The details of the policy outlined below are based on data, regulations, and recommendations from expert sources including but not limited to:
- Food and Drug Administration
- Centers for Disease Control and Prevention
- World Health Organization
- Federal Trade Commission
- Centers for Medicaid and Medicare Services
- Department of Health and Human Services
- Internal Review Boards
- Academic institutions
- Peer-reviewed journals
- Centers of excellence in healthcare
- Leading patient advocacy organizations
While Phreesia has attempted to articulate as many stances as possible in this content policy, there will always be grey zone cases. In these instances, we look to these bodies for clarity and direction.
User participation in third-party content
Phreesia’s software is designed to automate user (i.e., lay people or patients) and provider workflows before, during, and after the user visit. These workflows could include, but are not limited to, scheduling an appointment, capturing relevant intake information from the user and sharing it with the provider, or notifying the user via email or text that they have an upcoming appointment or preventive health screening due.
Third-party content may appear after these workflows. Prior to third-party content being shown, users are presented with an Authorization Form that, if accepted by the user, gives Phreesia permission to use the information the user provided in these workflows to present them with relevant, personalized content. The Authorization Form requires the user to click an “Accept” or “Decline” button: declining has no impact on a user’s healthcare treatment, and users who decline are not presented with third-party content.
After that point, when check-in has been completed and the user has chosen to receive messages, users have free choice to interact with content how they would like. Users can leave third-party content at any time. If any outbound links are present in third-party content, users are shown a pop-up informing them they are leaving the content environment and are no longer subject to Phreesia’s policy protections. Third parties receive engagement metrics for campaigns they sponsor in aggregate: no engagement data is ever shared with third parties at the individual level.
Participation in third-party research surveys
All research surveys for third parties fielded on the Phreesia platform begin with consent language. Consent language clearly indicates:
- the topic of the survey
- how much time is estimated to complete the questions
- if any honorarium is associated
- that questions are not being asked by their Provider and that responses will not be shared with their Provider
- that all responses are anonymous
- that all surveys are entirely voluntary and can be declined
If a user agrees to participate, all questions within surveys present users with the option to “decline to answer” so users can complete surveys while not providing information for all questions.
Users can also leave surveys at any time, from any screen: anonymous responses provided are retained if the user does not complete a survey. Some surveys offer users additional information or research opportunities. Users can decline such additional engagement, in which case all responses they have submitted until that point are kept in aggregated results (regardless of additional engagement). Those who are interested in further engagement are presented with the opportunity to provide their contact information for follow-up. Other than contact information, third party sponsors do not see information at the individual level under any circumstance.
Follow-up information and communications
Third-party content often allows users to receive additional information or communications from third-party sponsors. Users can decline to receive additional information or communications from any content: unless a user has specifically consented, they do not receive any additional information from third parties. We do not believe in the use of dark patterns, or intentionally deceptive design practices. We intentionally require several additional interactions to help ensure users are aware and choosing to receive additional information or communications from third parties: users must add their contact information (either by typing it in or selecting to use an auto-fill feature and confirming the contact information), provide an additional consent, and submit their contact information in all cases.
All third parties are expected to adhere to all regulatory and legal standards for additional information or communications made available to users via campaigns, as well as comply with expectations and standards outlined in contracts with Phreesia. Phreesia checks additional information or communications at the time of content deployment against this policy but does not actively monitor changes to those items while access remains on our platform. Any ongoing information or communications from third parties can only be delivered when patients provide additional consent that specifies third-party privacy rules will take effect for ongoing communications. Clear language appears to users at several moments throughout their experience indicating that the destinations and assets are not covered by or subject to Phreesia policies.
Building relevant audiences
We put consistent effort into assessing and improving how we support the autonomy, agency, and privacy of individuals checking-in on our platform. Foundationally, we believe users should have the right to receive personalized information in this moment: personalization needs to be treated with respect and diligence, and when done thoughtfully, supports better health outcomes. To that end, for both surveys and other information delivered to users:
- Content cannot be delivered to audiences younger than 18 years old: content can be designed to be shown to a parent or caregiver of a minor
- Content cannot be delivered to audiences facing cognitive impairments: content can be designed to be shown to a care partner or caregiver
- We will only allow for the segmentation of content in ways that align with our values, as determined by Phreesia in its sole discretion at any point in a campaign’s development process.
- We do not support geolocation-based targeting, or targeting that relies on pixels, cookies or similar technologies that could be used to identify patients in our network by third parties
- We exclude pregnant women, when data is available, from audiences for several types of content, i.e., weight loss content, etc.
- We do not deliver messages based on the contents of psychiatric notes, or any parameters regarding child abuse or neglect, or intimate partner violence.
- We do not deliver content about over-the-counter nutritional supplements and related items — such as vitamins, nutritional shakes, and information about CBD – unless in a specific medical context or for a defined medical need, as determined solely by Phreesia.
What third-party content is shared on our platform
Our primary function is delivering health and wellness content on behalf of different organizations to users transparently and with their consent to support conversations between a user and their care team or to otherwise assist them in being active participants in their health. There are some types of content that are incompatible with those goals, and we build all third-party content ourselves to ensure it aligns to our policies.
We do not present users with content:
- That promotes the use of opioids for acute or chronic pain conditions; tobacco products and related paraphernalia (electronic cigarettes, vaporizers, or any other products that simulate smoking); alcohol; weapons and related items (ammunition, explosives, weapon modification accessories, etc.); or other unsafe substances, products or supplements, as determined by Phreesia in its sole discretion and based on its review of clinical guidelines (i.e., essential oils cure cancer) that contribute to harm to the health and safety of the public.
- That discourages vaccination or advocates against vaccines.
- That promotes eating disorders or implies or attempts to generate negative self-perception in order to promote diet, weight loss, or other health- related products.
- Content about recovery or research about disordered eating always features an interstitial disclaimer allowing a user not to view it, and national helpline information with instructions for use for any users who may need it.
- That presents solicitations for financial contributions from users of any kind.
- Partisan advertisements for or from political candidates.
- Nonpartisan civic engagement content is allowed (i.e., “election day is on this date”)
- That presents out-of-date or inaccurate medical information, or that contains deceptive, false, or misleading claims like those relating to the effectiveness or characteristics of a product or service, including misleading health or weight-loss claims that set unrealistic expectations for users.
- We will provide resources to increase health literacy, media and digital literacy to help users better identify such information on other channels.
- That contains assertions about a competitive product for the same condition that cannot be substantiated and meet all applicable laws and regulations.
- That contains assertions or implications of a user’s personal attributes. This includes direct or indirect assertions or implications about a person’s race, ethnicity, religion, beliefs, age, sexual orientation or practices, gender identity, disability, physical or mental health (including medical condition), vulnerable social needs, family structure, etc.
- That advocates, recommends or suggests changing healthcare providers, unless in the context of clinical trial participation.
- That promotes suicide or self-injury.
- Content about recovery or research about suicide or self-injury always features an interstitial disclaimer allowing a user not to view it, and national helpline information with instructions for use for any users who may need it.
- That implies support or recommendation from providers in our networks or any groups other than the third party, that uses other copyrighted logos or brand names without consent, or that does not clearly indicate the supporter of the content within the content.
- That contains profanity or bad grammar and punctuation.
- That contains content that is disparaging of any race, ethnic group, religion, creed, sex, gender, sexual orientation, or other class of person.
- That contains depictions of people in sexually explicit or suggestive positions, or activities that are overly suggestive or sexually provocative. Nudity is occasionally allowed for the purposes of medical clarity and accuracy, at Phreesia’s sole discretion.
- That otherwise would be likely to be offensive to a reasonable person in the context of checking in for a doctor’s appointment.
- For non-therapeutic cosmetic procedures, it is Phreesia’s sole discretion as to whether content is permissible.
Content sponsors are responsible for understanding and complying with all applicable laws and regulations. Failure to comply may result in the cancellation of agreements. Phreesia will also not knowingly assist with the dissemination of content that puts the creator at risk legally, even if our platform may not technically be at risk. Please consult the institutions noted above for more information about content regulations.
Interpretations of this policy and how specific content does or does not align with this policy are at the sole discretion of Phreesia. These policies are subject to change at any time without notice.
Feedback on content
We carefully consider feedback on content from users and providers. If content is found to be offensive by what Phreesia deems too many users or providers in the Phreesia network we will either (a) edit targeting and associated guarantees, or (b) provide free creative services to update campaigns.