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Issues for Employer Plan Sponsors and Group Health Plans in the HIPAA Omnibus Rule (PDF)
Alston & Bird LLP
[Guidance Overview] Mar. 11, 2013 "For business associate agreements in place prior to January 25, 2013, that are compliant with HIPAA requirements, and so long as they are not modified or renewed from March 26, 2013, until September 23, 2013, the deadline for having business associate agreements that comply with the Omnibus Rule is the earlier of September 22, 2014, or the date the business associate agreement is modified or renewed. If your business associate agreements do not need to be amended, be sure not to accidentally trigger compliance with the new rules by renewing or modifying them before it is necessary to do so." MORE >> |
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