In a situation such as the one described by the commenter, the Department would look closely at whether the health plan was attempting to accomplish indirectly that which the Rule prohibits. In practical terms, if this rule applies to you, you must provide every patient with a privacy form and request his or her signature.
With respect to credit relationships, an institution establishes a customer relationship when it originates a consumer loan. NOTE: This module applies only to customers.
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An effective date, which may not be earlier than the date on which the notice is printed or otherwise published. California That.
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