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What's New In HIPAA

The next audit for HIPAA compliance has been a moving target for the last few years.  It was speculated that "Phase 2" as its being called, would start in fall of 2015 and extend into 2016.  However, we are now into the winter of 2015 and no announced date has been published.  

We can't really blame the Office of Civil Rights (OCR) since they have been very busy during this time handling HIPAA complaints and breach activity that has increased in volume each year. 
One task the OCR did complete in order to  move forward to implementing Phase 2, has been to contract with FCi Federal Inc. who is set to conduct the next round of audits.  (This according to Law360 article by James E. Bowers.​
In May of this year, a pre-audit screening was sent to a pool of covered entities. However, no additional information has come out whether this screening letter represented a final list of companies that will be audited or if more is yet to come.  The deciding factor is the government budget for this activity.

What you can be certain of is that Phase 2 will target non-compliance identified in its pilot audit and subsequent enforcement actions.
In 2011, the pilot audit identified the most significant failing by providers, health plans, and clearinghouses, the number one item was the lack risk assessment performed.  Nearly two-thirds audited audited failed in this most critical of steps.

In addition to failing at the performance of a risk assessment there was inadequate workforce training and a general disregard of the importance of having a healthy HIPAA program.  It stands to reason that this too will be part of the focus of Phase 2.

Though the audit official start date has not been posted to any published calendar, you will want to be certain to take whatever time is left now to at least evaluate your own program.  A good place to start is to review the protocol published on the Department of Health and Human Services.


Next Government Audit To Be Conducted Early 2016?
By Andrea S. Driscoll,  June  2016

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