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ABC March 28, 2005, Coment Letter to DOL, IRS, and HHS Regarding HIPAA Portability Proposed Rules (PDF)
American Benefits Council 
[Opinion] Mar. 31, 2005
8 pages. Excerpt: The purpose of this letter is to raise concerns regarding the following proposed rules: I. Counting creditable coverage;II. Tolling of the special enrollment period; III. Special enrollment requests; IV. Newborn enrollment; and V. FMLA educational statement.
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