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The request also would need to identify the data being requested and include an attestation that (1) the ASM participant is requesting this beneficiary-identifiable data as a HIPAA covered entity, or as part of a HIPAA covered entity, and (2) the ASM participant's request reflects the minimum data necessary for the ASM participant to ( conduct activities that are described in the first or second paragraph of the definition of health care operations at 45 CFR 164.501

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Royer, A