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Text of Letter to HHS Requesting Clarification and Guidance on HIPAA/HITECH Final Rule on Refill Reminder Programs (PDF)
Center for Democracy & Technology Link to more items from this source
[Opinion]
June 10, 2013

"[The authors] are concerned that language in the preamble to the Final Rule ... [will] jeopardize the sending of refill reminders. Specifically, [they] request that OCR issue additional guidance that: [1] Makes clear that when pharmacies enter into business associate relationships with third parties in order to carry out their refill reminder programs, such relationships do not automatically trigger a patient authorization requirement; and [2] Clarifies that permissible 'reasonable in amount' payment for such medication adherence programs explicitly includes all reasonable direct and indirect costs related to them."

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