Smart Benefits: Phase 2 HIPAA Audits Underway
Monday, April 25, 2016
As a part of its efforts to assess compliance with HIPAA, the HHS Office for Civil Rights (OCR) has begun its next phase of audits of covered entities and their business associates. To help organizations understand the scope, process and timelines of the Phase Two audits, HHS has published information on its website, which addresses the following topics.
Who Can Be Audited?
Every covered entity and business associate is eligible for an audit. These include covered individual and organizational providers of health services; health plans of all sizes and functions; health care clearinghouses; and a range of business associates of these entities.
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For Phase Two, OCR has identified pools of covered entities and business associates that represent a wide range of health care providers, health plans, health care clearinghouses and business associates. After verifying contact information, OCR has begun sending a questionnaire designed to gather data about the size, type, and operations of potential auditees to covered entities and business associates. The responses, along with other information, will be used to develop pools of potential auditees for the purpose of making audit subject selections. OCR will choose auditees through random sampling of the audit pool and notify them of their participation.
How Will The Audits Work?
OCR plans to conduct desk and onsite audits for both covered entities and their business associates. The first set of audits will be desk audits of covered entities followed by a second round of desk audits of business associates. Entities selected for an audit will be sent an email notification of their selection and will be asked to provide documents and other data in response to a document request letter. Audited entities will submit documents on-line via a new secure audit portal on OCR’s website. Fewer in-person visits will take place during these Phase Two audits than in Phase One.
What Is The Timeline For The Audits?
In the coming months, OCR will notify the selected covered entities about their selection for a desk audit. The OCR notification letter will include initial requests for documentation. OCR expects covered entities to submit requested information via OCR’s secure portal within 10 business days of the date on the information request. All documents must be in digital form and submitted electronically via the secure online portal.
After reviewing the documents, the auditor will provide the auditee with draft findings. Auditees will have 10 business days to review and return written comments, if any, to the auditor. The auditor will complete a final audit report for each entity within 30 business days after the auditee’s response.
All desk audits in this phase will be completed by the end of December 2016.
Rob Calise is the Managing Director, Employee Benefits. of Cornerstone|Gencorp, where he helps clients control the costs of employee benefits by focusing on consumer driven strategies and on how to best utilize the tax savings tools the government provides. Rob serves as Chairman of the Board of United Benefit Advisors, and is a board member of the Blue Cross & Blue Shield of RI Broker Advisory Board, United HealthCare of New England Broker Advisory Board and Rhode Island Business Healthcare Advisors Council. He is also a member of the National Association of Health Underwriters (NAHU), American Health Insurance Association (AHIA) and the Employers Council on Flexible Compensation (ECFC), as well as various human resource associations. Rob is a graduate of Bryant University with a BS in Finance.
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