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By April 14, 2004, All Group Health Plans Must Comply with HIPAA Privacy Rule (PDF)
Neal, Gerber & Eisenberg LLPLink to more items from this source
Apr. 1, 2004
Excerpt: The employer-sponsored health benefit plans that must comply with the Privacy Rule include cafeteria plans with flexible spending health benefit accounts. The only health benefit plans that will not have to comply with the Privacy Rule after April 14 are those with less than 50 participants that are administered solely by their employer-sponsors. Those plans are not subject to HIPAA at all.

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