[ Wednesday, September 11, 2013 ]


RX Refill Reminders Guidance Coming: HHS is going to issue guidance by September 23, 2013 outlining and explaining HIPAA's requirements relative to prescription drug refill reminders.  Many big pharmacy companies have stopped providing the reminders due to confusion caused by unclear language in the "marketing" provisions of the Omnibus Rule, and one group actually sued HHS.  That group, Adheris, and HHS have agreed, in a joint order in their court case, to put the case on hold while HHS puts together guidance.

The marketing provisions of the Omnibus Rule are poorly thought-out and poorly drafted, and the prescription reminder part is actually one of the more clear provisions, in my opinion.  Hopefully, HHS will take on the entire marketing provision and fix it.

Jeff [1:01 PM]

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