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HIPAA Audits – Not a Question of if, but When

Susan McAndrew, Office of Civil Rights deputy director for health information privacy spoke at the HIMSS Conference on 2/24/14. As the OCR already made known, it plans to resume its HIPAA compliance audit program this year following the Pilot HIPAA Audit program in 2012. Now, more information is available on the progress towards the start of those audits. Ms. McAndrew addressed the topic, noting that “hopefully in the coming months you’ll see actual activity that will start the audit process.”

In regard to that process, the Department of Health and Human Services (HHS) posted a notice for comments in the Federal Register concerning Covered Entity and Business Associates Pre-Audit Survey. In this posting, HHS proposed a pre-audit survey of up to 1200 HIPPA covered entities (health plans, health care clearinghouses, and certain health care providers) and business associates (entities that provide certain services to a HIPAA covered entity) to assess the suitability of respondent covered entities and business associates for audits. The survey will enable OCR “to assess the size, complexity, and fitness of a respondent for an audit.”

Now is the time to get prepared to be HIPAA happy instead of HIPAA sad if HHS comes knocking at your door and you are unprepared for a HIPAA audit.

To review the 2/24/14 Federal Register posting, here’s a link:
https://www.federalregister.gov/articles/2014/02/24/2014-03830/agency-information-collection-activities-proposed-ollection-public-comment-request

By Denise Bloch

Denise Bloch

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