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https://disruptedphysician.blog/2017/06/29/how-your-employee-assistance-program-eap-is-at-risk-for-fraud-and-abuse-what-you-need-to-know-about-the-php-blueprint-and-new-paradigm-3/
How your Employee Assistance Program (EAP) is at Risk for Fraud and Abuse: What you need to know about the "PHP-Blueprint" and "New Paradigm"