[ Friday, September 20, 2013 ]
Refill Reminder Guidance:
Jeff [12:25 PM]
As I noted last week
, HHS agreed, in connection with a suit filed against it, to offer some guidance on how the refill reminder exception to the marketing prohibition is supposed to work. If you've spent any time trying to figure out what you can and can't do under HIPAA relating to marketing, you know it's frustratingly confusing. So troubling that Adheris sued HHS to try to get a federal court to determine what it could and couldn't do.
Now, HHS has provided some guidance
, along with some FAQs. The jury's still out on whether this will be enough.
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