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April 14, 2004 HIPAA Compliance Deadline for Small Employers (PDF)
Brown Rudnick Berlack Israels 
Apr. 16, 2004
4 pages. Excerpt: Many employers may not realize this, but HIPAA explicitly requires that the privacy requirements be added to the plan document and summary plan description for the group health plan. This, of course, begs the question of whether the employer has a plan document and summary plan description for the group health plan. In most instances, the answer to this question is no.
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