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What's New In HIPAA

Next Government Audit To Be Conducted Early 2016?
By Andrea S. Driscoll
December 3, 2015

The next audit for HIPAA compliance has been a moving target for the last four 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 announcements on a 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.)
When will the next audit rounds begin?  "Phase 2" is speculated to begin in early 2016.  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.

More to come...

More to come...

What you can be certain of, is that Phase 2 will target noncompliance 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 was not performing a risk assessment.  Nearly two-third of the population audited failed this most critical step in compliance.
In addition to failing at risk assessments 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.

More to come....

More to come...

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 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 website. 
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