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An analysis of CVS’ rewards program and its ties to HIPAA

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CVS Caremark rolled out their new ExtraCare Pharmacy and Health Rewards program in February as an extension of their original rewards program that offers deals on in-store products. The prescription rewards program offers pharmacy customers $5 in store credit for every 10 prescriptions filled. Each person enrolled in the prescription program can receive up to $50 in store credit annually.

A Los Angeles Times analysis of the rewards program revealed that the pharmacy is asking patrons to sign a HIPAA authorization to join the program, but the company fails to clarify the nature of HIPAA for those who may not understand it. The authorization permits CVS to record the prescription earnings of each enrollee, according to the Times. It also asks patients are to acknowledge that their “health information may potentially be re-disclosed and thus is no longer protected by the federal Privacy Rule” but does not indicate what entities the information might be shared with, the report said.

A CVS spokesman told the Times that CVS does not “sell, rent, or give personal information to any non-affiliated third parties.” However, the spokesman would not comment on whether he believed CVS was adequately describing HIPAA to customers or what the potential consequences could be for those who sign away their privacy, the Times reported. He also declined to comment on the details of the potential re-disclosure of patient information, according to the report.

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