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Memories of Health Insurance Portability and Accountability Act (HIPAA) compliance likely have long faded for many HR and benefits professionals. You distributed your Privacy Notices, trained your staff, conducted a “risk assessment” of your information systems under the Security Rule, and formally adopted a thick binder of HIPAA Privacy and Security policies. HIPAA, like Y2K, has come and gone, and health plan compliance has turned to bigger and more pressing issues, right?

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