PHI is visible and audible at the counter
The Privacy Rule requires appropriate administrative, technical, and physical safeguards for PHI and limits uses and disclosures to the minimum necessary. Screens facing the line, labels in open bins, and counseling within earshot are all safeguard questions, and the policies have to say how the pharmacy handles them.
45 CFR 164.530(c) · 164.502(b)
In the programWritten safeguard policies with staff acknowledgments, role-based training that covers the counter, and the documentation trail in one record.
