No. With respect to obtaining authorizations from patients already enrolled in these programs, OCR will not determine that a covered entity is in violation of the marketing provisions if it has not obtained authorizations from all existing patients to whom it is making such communications by the September 23, 2013, compliance date, provided the patients from whom authorizations have not been obtained have not opted out or declined to receive such communications and the patients’ authorizations are obtained at the next time their prescriptions are renewed,
