I think that since this is a total opt-in, if your sign-up
form had the company clearly identified, and spaces for address, it would no
more be PHI than the same form in a supermarket (which I have seen, even filled
out a few when my daughter was on the way [15 years ago]).
It gets a little iffy if you support this with a checkoff
indicator in your database, and generate the list from the database.
Do any ot the gurus out there know if this crosses the line
into Marketing, and if so, is it permitted? If it is permitted, it would
be required in your NPP.
The need for a BAC is less iffy. I thinka BAC
would not be required, since the rep isn't doing anything for YOU, but is
acting in its own self-interest (providing a service to the patient in hopes of
future sales).
The opinions expressed here are my own and not necessarily the opinion of
LCMH.
Douglas M. Webb
Computer System Engineer Little Company of Mary Hospital & Health Care Centers [EMAIL PROTECTED] "This electronic message may contain information that is confidential
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- BA contract with Reps Rlh00023
- Doug Webb