Federal Register. Burr WE, Dodson DF, Polk WT. NIST Special Publication 800-63 Version 1. Centers for Medicare Medicaid Services CMS HHS. Final rule. Health insurance reform: security standards. 8381.
The part of the Statement that deals with the FCA s expectations may encourage policyholders to take action against insurers for misrepresentation of the coverage provided and/or against brokers for negligent advice, or at least to reserve their rights against those entities, which could give rise to satellite disputes.
Once the insurers who will be involved in the procedure have been identified as a result of the responses that the FCA has required by 15 May, the relevant wordings and issues need to be identified and agreed. The FCA appears to hope that SMEs at least would refer any such disputes to the FOS, rather than commencing litigation or arbitration claims.
At this time, if not before, it must be expected that policyholders who are prepared to engage in the process will want to have their say about the insurers, wordings and issues to be involved and the details of the procedure itself.
Are there any legal or code requirements for companies to have specific standard operating procedures SOPs governing advertising activities or to employ personnel with a specific role? There are no provisions under the relevant laws that require a company to have internal standard procedures for drug advertising or require employment of personnel to carry out such activities. There are no provisions under the relevant laws that specifically require such arrangements.
If so, what is the procedure for approval? If so, what aspects should those SOPs cover and what are the requirements regarding specific personnel? Must advertising be approved in advance by a regulatory or industry authority before use?