Utilizing WhatsApp in State Medicaid and Marketplace Outreach Efforts
Melissa Morales, Kenzie Perrow and Candace Tyler, GMMB; Alexandra Krasovec, Manatt Health
State Medicaid and Marketplace agencies continue to advance innovative strategies to connect with existing members and engage potential members. In today’s dynamic digital landscape, states have various tools at hand to reach their audiences efficiently and effectively with important information.
WhatsApp, a globally adopted direct messaging platform, has risen in popularity with users in the U.S. and shown increased potential for reaching specific populations. While WhatsApp is commonly used as a direct-to-consumer tactic, this expert perspective explores strategies and best practices for states that are interested in using WhatsApp in their member outreach and support efforts.
Background
WhatsApp is a free instant messaging service owned by Meta, the parent company of popular social media sites like Facebook, Instagram, and Threads. Compatible with Android and iPhone devices, WhatsApp allows users to send direct messages in multiple formats, including texts, calls, images, videos, links, contacts, and voice messages. WhatsApp’s extensive features, combined with its simplicity of use, make the application popular with users who look to the platform for a streamlined communications experience.
WhatsApp claims a significant user base in the U.S., with 100 million users as of July 2024. And people use it frequently: 2020 research shows 50% of U.S. users use it daily, 78% engage with it weekly, and 91% check it at least once a month. WhatsApp’s presence among U.S. internet users is particularly strong with younger adults, with 37% of 18 to 34 year-olds and 27% of 35 to 44 year-olds using the app. Geographically, urban areas lead in WhatsApp usage, with 32% of urban residents using the app, followed by 22% of suburban residents and 13% of rural residents.
WhatsApp is also available in over 40 languages on iOS and 60 on Android devices, broadening the application’s appeal across non-English speaking communities. In 2023, 54% of Latinx adults and 51% of Asian adults in the U.S. reported using WhatsApp, compared to 31% of Black adults and 20% of White adults. With the platform’s diverse usage patterns and large-scale reach of nearly one-third of the U.S. population, WhatsApp has powerful potential to help states engage specific audiences.
WhatsApp Features
WhatsApp allows for two main account types: WhatsApp personal accounts and WhatsApp Business accounts. A WhatsApp personal account is designed for individual use, allowing users to communicate with friends, family, and other personal contacts and engage with communities and topic-based groups that may interest them. WhatsApp Business, which is the best option for official state Medicaid agencies and Marketplaces, is designed for entities to connect with consumers and boasts several features, including:
- Business profiles: Allows businesses to create profiles with important information such as business descriptions, emails, locations, and websites.
- Customer support: Real-time customer service can immediately address questions, complaints, or feedback.
- Automated messages: Allows businesses to send greetings, away messages, and other quick replies to simplify member communications.
- Labels: Helps businesses categorize chats and contacts to segment marketing and outreach messages.
- Verifications: Business accounts can be verified by WhatsApp, adding an additional layer of trust for consumers.
Business Channels, Groups, and Communities
WhatsApp offers three main avenues for communicating with users: Business Channels, Groups, and Communities. Each path of communication has distinct functionalities and advantages for states to consider. To help states understand which path is right for them, the following chart compares the key capabilities and best use-case scenarios for each.
In addition to sharing outreach resources with partner organizations and stakeholders, states can use WhatsApp as a customer support tool, providing real-time support to users through the platform’s direct messaging capabilities. States can create automated responses to frequently asked questions, set response time estimates, respond immediately to inquiries, and more. States should ensure members know they can receive support via WhatsApp by sharing a QR code or “click to chat” link in all resources that share the organization’s contact information.
Quick Tip: WhatsApp administrators may invite people to start conversations, join groups and communities, or follow business channels by sharing a link. Administrators can send invite links by sharing through the app, utilizing link share integrations, copying a link, or generating a QR code. Because anyone with an invite link can join a group or community or follow a channel, admins should be careful to share links with only those they intend to join.
Applications for State Agencies
Reaching Multicultural Communities
While platforms like iMessage and Facebook Messenger are more commonly used across the U.S. population, specific communities prefer WhatsApp over these more dominant applications. Many of the features that make WhatsApp a global success are the same features that attract multicultural communities, including:
- Availability in multiple languages.
- Free usage with a phone plan and internet access.
- Simplicity of use and user-friendly interfaces.
- Equal quality on Android and iOS systems.
- The ability to share a variety of media formats across devices and on desktop.
The Latinx community has a distinct presence on WhatsApp, with 54% of Latinx adults in the U.S. reporting using the application in 2023. Many Latinx individuals in the U.S. have a connection with WhatsApp that runs deeper than its features: they have family members in Latin American countries where WhatsApp is a primary communications platform and use the app to communicate with family and relatives. In 2023, most of the population in Chile (93.8%), Brazil (93.4%), and Mexico (92.2%) used WhatsApp for its messaging services.
As an example of WhatsApp’s role in the Latinx experience in the U.S., during the COVID-19 pandemic the Centers for Disease Control and Prevention (CDC) used the platform to encourage vaccinations in Spanish-speaking communities. Use of the app helped dispel misinformation, share critical updates, and increase vaccinations among a population that was more susceptible to misinformation about COVID-19 than others. As states consider using WhatsApp in outreach efforts, this strategy is an example of meeting audiences on the platforms that resonate most with them to relay vital information about their health.
Partner Engagement
Some states have begun experimenting with using WhatsApp in their outreach plans. In 2023, Maryland Health Benefit Exchange (MHBE) began using WhatsApp to share resources with partner organizations that were already using WhatsApp Groups to disseminate information to their local communities. MHBE created a Maryland Health Connection Business account and established a partner group chat. Through WhatsApp, MHBE generated a QR code to invite partners—particularly those serving Latinx Marylanders—through direct outreach. The chat has been used to share flyers and social media content (in English and Spanish), invite stakeholders to events, and triage questions from partners.
WhatsApp vs. SMS Text Messaging
WhatsApp and SMS text messaging are pivotal communication tools for states that want to engage members more effectively. While similar in their basic functionalities, there are key differences between the methods that may make WhatsApp more appealing to states, including:
- Cost: SMS text messaging relies on users having paid cellular network plans, some of which may require the user to incur per-text charges and/or impose text usage limits. WhatsApp works over a Wi-Fi connection and does not require registered users to incur a charge to send or receive messages while using the app, making it more cost-effective for users with access to Wi-Fi.
- Notifications: Unlike SMS text messages, WhatsApp notifications do not go directly to users’ phones. Users must opt into notifications through the app to receive updates from businesses.
- Encryption: WhatsApp provides end-to-end encryptions for all messages sent through the app, ensuring that only the sender and recipient can read the messages. SMS text messages are not encrypted.
- Integrations: WhatsApp allows integrations with other apps and services, such as sharing locations with Google Maps and sending documents.* SMS text messages have limited integration capabilities and are limited to sharing contact information or links.
*States are encouraged to limit the documents shared through WhatsApp to public-facing materials such as flyers, social media content, graphics, and similar resources to maintain the security of confidential information.
While WhatsApp is an emerging tool that can be a useful alternative to standard practices, there are still some advantages to SMS text messaging strategies, such as:
- Usage: Over 80% of people in North America use SMS compared to 29% who use WhatsApp.
- Reach: Since most phones have built-in SMS capabilities, states can reach larger audiences through SMS text messaging. Users must download the WhatsApp application to receive messages through the platform.
- Timeliness: Time-sensitive messages such as application deadlines are best sent through SMS, since most people can receive texts messages immediately without having to download an app.
- Open rates: SMS campaigns have an average open rate of 98% and click-through rates of over 36%.
By understanding the individual and shared strengths of these platforms, states may leverage WhatsApp and SMS text messaging strategies to deliver important communications to both broad audiences and hard-to-reach populations.
Security
States should take security precautions across all digital practices, especially when implementing WhatsApp and SMS outreach strategies. States may consider taking the following steps when using both platforms:
- Avoid sharing sensitive information: Use caution when sharing sensitive information through digital platforms. Consider using encrypted email or secure file-sharing platforms whenever possible.
- Update applications and devices: Regularly update applications and operating systems across devices to ensure you have the latest security features.
- Be aware of phishing attempts: Exercise caution when receiving information from unknown sources. Do not click links or respond to requests for personal information from unfamiliar senders.
- Use two-factor authentication: Two-factor authentication (2FA) ensures the security of information and adds an additional layer of protection against unauthorized access to online accounts.
WhatsApp vs. SMS Policies and Implications for States
SMS is heavily regulated. Numerous statutes and regulations proscribe or limit SMS activity, including but not limited to the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227 et seq., its implementing regulations, 47 C.F.R. 64.1200 et seq., and state law equivalent statutes. These statutes and regulations restrict the use of certain equipment, impose consent requirements, and limit or prohibit outreach to phone numbers on federal and state Do Not Call lists, among other things. Many of these statutes, including the TCPA, also provide consumers with a private right of action and allow for recovery of damages (e.g., actual, statutory, and/or treble). Violations are also subject to enforcement by the Federal Communications Commission (FCC) and state Attorneys General. Cellular carriers, who are subject to regulation and enforcement by the FCC, also monitor and regulate SMS activity on their networks, and can impose penalties (e.g., increased filtering, suspension of service, termination) based upon such monitoring. Text message platforms and providers may act as an extension of such monitoring, and many impose their own authorized use requirements.
Courts have also applied the TCPA to messages sent using online messaging platforms and delivered to the recipient’s cell phone via SMS. See, e.g., Johnson v. Yahoo! Inc., No. 14 CV 2028, 2018 WL 835339, at *1 (N.D. Ill. Feb. 13, 2018) (applying TCPA to Yahoo! Messenger messages delivered via SMS).
While the TCPA has not been construed to apply to WhatsApp messaging conducted wholly within the WhatsApp platform, the language of the statute may permit such a construction. WhatsApp messages are similar to SMS because they have the capacity to invade consumer privacy and may be unwanted. See In the Matter of Targeting & Eliminating Unlawful Text Messages Rules & Reguls. Implementing the Tel. Consumer Prot. Act of 1991, No. 02-278, 2023 WL 2582658, at *2 (2023) (the purpose of the TCPA rules is, in part, to combat illegal text messages because they invade consumer’s privacy and are vehicles for fraud). Further, because the FCC and Congress are concerned with spam text messaging, it is possible that a court could liberally interpret the TCPA provisions to apply to WhatsApp messages, which are delivered to a cell phone at a cell phone number, albeit via the app. See 47 U.S.C. 227(b)(1)(a)((iii) (TCPA applies to “calls [including text messages] delivered to any telephone number assigned to a paging service, cellular telephone service, specialized mobile radio service, or other radio common carrier service”). State statutes and regulations that apply to SMS activity might be subject to similar applications.
CTIA-The Wireless Association, formerly the Cellular Telephone Industries Association, is a trade group representing wireless communication sectors. CTIA has developed a set of voluntary best practices–Messaging Principles & Best Practices (“Guidelines”)–to provide guidelines on the exchange of information between cloud-based platforms and wireless provider messaging networks. These Guidelines generally impose consumer opt-in and other disclosure requirements on message senders. While not “regulations,” many SMS platforms and providers require senders to comply with CTIA Guidelines as part of their Terms of Service and/or Authorized Use Policies. Since WhatsApp has SMS interoperability, the Guidelines may apply to WhatsApp messages.
WhatsApp messaging is also subject to platform-specific limitations and requirements. This includes an obligation to obtain an opt-in (as discussed above) and to honor all requests (whether received on or off WhatsApp) by a person to block, discontinue, or otherwise opt out of communications via WhatsApp, including removing that person from a contacts list. Consumers who receive unwanted messages may report or block businesses, and WhatsApp reserves the right to limit content that consumers receive from businesses with multiple complaints—potentially impacting the success of outreach efforts.
For more guidance on SMS policies, see SHVS’ expert perspective, Optimizing SMS Strategies for Outreach to Medicaid and Marketplace Enrollees.
Best Practices for Using WhatsApp
Considerations for Getting Started on WhatsApp
When setting up a WhatsApp Business account, states should ensure their profile is up to date with all the relevant information needed for members to recognize the account as the official profile of the state agency. WhatsApp Business profiles should include:
- State agency or marketplace name
- Business category
- Profile image or company logo
- Location
- Contact information (website, email, phone number, etc.)
- Business hours
Meta Integrations
Meta enables WhatsApp to integrate seamlessly with other digital channels acquired by the conglomerate. Entities can link their WhatsApp Business accounts with existing Facebook or Instagram business profiles, allowing WhatsApp accounts to appear as a contact option on the Facebook pages or Instagram business accounts they are linked to. By integrating WhatsApp accounts with other Meta-owned platforms, states can maximize their organization’s discoverability and increase opportunities for members to find support.
Do’s and Don’ts for WhatsApp
States may consider the following best practices when using WhatsApp in their member outreach efforts.
- Do:
- Ask for permission and respect boundaries: Always ask for permission from individuals before adding them to a WhatsApp group. If someone joins a group and then removes themselves, honor their decision.
- Communicate with known contacts: Only send messages to those who have initiated contact or have requested to be contacted on WhatsApp.
- Set response time expectations: Autoresponders can help businesses manage users’ expectations and provide alternative options such as links, email addresses, or phone numbers.
- Don’t:
- Send bulk messages: Be mindful of how frequently you are sending messages to users. Do not overwhelm users with bulk messages or auto-dials on the platform. WhatsApp can detect and ban accounts that send unwanted and/or unconsented automated messages.
- Use outside contact lists: Do not share phone numbers without consent or use data obtained from prohibited sources to message users on WhatsApp or add them to groups.
- Harvest personal information: Avoid automated extraction of information from WhatsApp for unpermitted purposes.
Opt-In Regulations
States must consider opt-in regulations when communicating with members via WhatsApp Business accounts. Businesses may only contact users on WhatsApp if:
- The user has given a business their mobile phone number.
- The business has received opt-in permission from the user confirming they want to receive messages or calls from the business through WhatsApp.
For more information and best practices about WhatsApp’s opt-in policies, visit WhatsApp.com.
Spam and Misinformation
States should be mindful of WhatsApp’s increased exposure to spam and misinformation. This is especially crucial when targeting diverse populations that are more likely to turn to—and trust in—social media for health-related information.
Data show that 49% of Latinx adults frequently find health-related information and advice on social media platforms, with 32% having some level of trust in the health information they see on WhatsApp. This high engagement level highlights the importance of providing accurate and reliable health information. Despite Latinx adults with lower levels of educational completion being more likely to trust misinformation related to health issues, most individuals do not believe what they see—demonstrating the need for addressing health misinformation in accessible ways and allowing states the opportunity to intervene through targeted outreach and support.
Available Resources
States can find more information and resources on using WhatsApp for outreach and communications efforts on the WhatsApp Blog.