"[T]he Final Rule departs from prior versions of the rule in that it requires individual authorization for all communications, whether for 'treatment' or 'health care operations' purposes, where the covered entity receives financial remuneration for making the communications from a third party whose product or service is being marketed. 'Financial remuneration' means direct or indirect payment from or on behalf of a third party whose product or service is being described.... [T]he Final Rule retains a narrow exemption ... for refill reminders and other communications that are about a drug or biologic that is currently being prescribed for the individual."  MORE >>