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HIPAA: Health Care, Employers, Confusion, and Controversy
Wiley Rein LLP via Lexology; free registration may be required Link to more items from this source
[Guidance Overview]
Mar. 14, 2014

"The core problem is that the line between the 'group health plan' and the employer/plan sponsor is a legal fiction. HHS has established a regulatory framework, covering virtually every employer that provides any kind of health benefits to its employees, which is based on the idea that there is a distinction between this 'group health plan' and the 'plan sponsor' of that health plan.... So, HHS has created a complicated set of regulatory provisions based on a legal fiction. Therefore, there has always been real confusion about even these core rules."

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