Excerpt: HHS has also proposed a number of changes of particular concern to employers, including: a specific reference in the regulations to permit the sharing of enrollment and disenrollment data with plan sponsors without the need to amend the plan document; an acknowledgement that PHI does not include 'employment records'; and enabling a 'hybrid entity' to define which of its parts are the 'covered entity,' for example the self-insured health plan, and which are non-covered components ...