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Worked in the space, and GoodRx would get transactions off the same pipelines every other PBM did... If that doesn't make them a CE, then somebody has some 'sp
by salawat 4y ago
Worked in the space, and GoodRx would get transactions off the same pipelines every other PBM did...
If that doesn't make them a CE, then somebody has some 'splaining to do.
- jkaplowitz 4y agoI think you're right that someone has some 'splaining to do, but that someone is the legislators who specified such a narrow scope, and/or possibly the regulators if they didn't incorporate the broadest scope allowed by the law into the regulations. Here is who qualifies as a CE: https://www.hhs.gov/hipaa/for-professionals/covered-entities/index.html https://www.hhs.gov/hipaa/for-professionals/covered-entities... How does GoodRx fit into any of these categories? I don't see it.
- SkyPuncher 4y agoIt seems unclear is a PBM is actually required to be HIPAA compliant. It's possible some health care providers (think large hospitals) enforce HIPAA via contractual obligations without federal law directly requiring PBMs to be covered entities. That would give a path for GoodRx to interact without being in violation of HIPAA.
- salawat 4y agoPBM's are definitely CE's under HIPAA.