SB 208 Summary

• Retailers offering pharmacy rewards programs must provide consumers with a written plain language summary of program terms and conditions before enrollment (effective July 1, 2014)

• If a HIPAA authorization form is required for program participation, retailers must include specific information adjacent to the signature line regarding: permitted uses of health information, whether data will be shared with third parties, which third parties have access, how to revoke authorization, and the right to receive a signed copy

• Retailers must define key terms including "HIPAA," "HIPAA authorization," "protected health information," and "marketing" in promotional materials, plain language summaries, and enrollment forms where these terms are used

• Violations of the disclosure and definition requirements constitute unfair or deceptive trade practices under state law