10:05 a.m. |
Discussion
I. Marketing Issues
- A. Whether the current structure of marketing coverage under the rule
generally should be continued.
- 1. Currently, health-related marketing is considered a part of health care
operations (and therefore subject to the one-time general consent) if it is (1)
face-to-face, (2) involves only items of nominal value, or (3) complies with
the provisions for third-party marketing (including disclosure and
opt-out requirements).
- 2. Possible changes:
- a. Return to the position of the NPRM, under which no marketing activities
would be permitted without a prior authorization.
- b. Permit all marketing without prior authorization (and not just the 3
exceptions)?
- B. Consideration of various specific recommendations that, if adopted,
would revise or clarify provisions under any of the above structures.
- 1. Definition of Marketing
- 2. Prior Authorizations
- 3. Opt-out/Opt-In Provisions
- 4. Disclosure of Marketing Arrangements
- 5. Special Case Marketing Considerations- Minors and Sensitive
Information
- 6. Regulations of Methods
II. FUNDRAISING ISSUES
- A. Whether the current structure of fundraising coverage under the rule
should be continued.
- B. Consideration of various specific recommendations that, if adopted,
would revise or clarify provisions under any of the above structures.
- 1. If current system retained, should the list of approved demographic
information for release be amended to include the name of doc and/or dept in
which the patient was seen.
- 2. If the current system is replaced with one requiring prior
authorization for fundraising, should the authorization form be simplified for
fundraising?
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Subcommittee |