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Are You Compliant? Next Phase of HIPAA Compliance Dates Starts April 14 (PDF)
Neal, Gerber & Eisenberg LLP 
Apr. 1, 2004
Excerpt: Every covered group health plan that is self-funded in part or whole or that creates or receives protected health information beyond enrollment data and summary health information (which is essentially aggregated claims data without individual identifiers) must comply fully with the Privacy Rule.
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