HIPAA Audit Lottery Begins This Month
HHS's HIPAA enforcement arm, OCR (Office for Civil Rights), will begin HIPAA privacy and security audits this month, November 2011. Every "covered entity" is eligible, including covered entities that are health plans provided by employers. 150 covered entities will be chosen for what is described as a "pilot phase" that will conclude by December 2012.
Selected covered entities will be notified in writing by the OCR and will be expected to provide requested information within 10 business days. OCR projects a total audit period of 90 business days, including 3-10 business days for the onsite audit that follows up the written documentation.
HHS says the audits are "primarily a compliance improvement activity" that will help determine what technical assistance should be developed by the government agency. If there is any serious compliance issue, a compliance review may be conducted and penalties considered.
If you are one of the lucky few selected for the HIPAA audit, act promptly and take the process seriously. Consider having your counsel or other HIPAA compliance advisors preview your written documentation and discuss the audit process ahead of any onsite visit by the OCR.
Nelson Mullins Executive Compensation and Employee Benefits attorneys are ready to assist with your compensation and benefits related matters in a cost-effective and responsive manner. Please contact one of our Executive Compensation and Employee Benefits partners or the Nelson Mullins attorney with whom you work. Also, be sure to visit our Employee Benefits Blog.
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