[ Monday, May 06, 2013 ]
The HIPAA Omnibus Rule Blows Up Refill Reminders:
Jeff [5:01 PM]
Some of the hardest components of the Omnibus Rule to figure out are the changes to marketing and restrictions on sale of PHI. Any communication urging the recipient to purchase a good or service is marketing. When a physician gives you a prescription, he's urging you to buy that drug; is that marketing? There is an exemption that allows for delivery of that prescription, since it's for treatment of the individual.
However, the exemption doesn't apply if the provider is paid for making the communication. Because of that limit on the exemption, CVS has decided to stop sending refill reminders
, since they were being paid to do so by the manufacturers of the drugs that were being refilled.
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