ARTICLE
5 October 2015

Second Phase Of HIPAA Audit Program Imminent

DP
Day Pitney LLP

Contributor

Day Pitney LLP logo
Day Pitney LLP is a full-service law firm with more than 300 attorneys in Boston, Connecticut, Florida, New Jersey, New York and Washington, DC. The firm offers clients strong corporate and litigation practices, with experience on behalf of large national and international corporations as well as emerging and middle-market companies. With one of the largest individual clients practices on the East Coast, the firm also has extensive experience assisting individuals and their families, fiduciaries and tax-exempt entities plan for the future.
The long-awaited second phase of the Health Insurance Portability and Accountability Act (HIPAA) audit program is finally upon us.
United States Food, Drugs, Healthcare, Life Sciences
To print this article, all you need is to be registered or login on Mondaq.com.

The long-awaited second phase of the Health Insurance Portability and Accountability Act (HIPAA) audit program is finally upon us. The U.S. Department of Health and Human Services' Office for Civil Rights (OCR) recently announced that it has selected Virginia-based FCi Federal as the vendor to conduct the next phase of HIPAA audits. Further, OCR has begun compiling the list of potential auditees for examination, which will include both covered entities and business associates.

It is important that potential auditees maintain readiness for audit examination because HIPAA noncompliance can be costly and disruptive to an organization. Themost commondeficiency found by OCR in its phase one audits was a failure of an organization to conduct a security risk assessment to identify and mitigate risks to protected health information (PHI), e.g., PHI on exposed servers, laptops unencrypted, default passwords not changed, security software not up-to-date, and inadequate training. As hard as it is to believe, this "lesson learned" still has not been implemented by many HIPAA entities, for as recently as a few weeks ago OCR announced a $750,000 settlement with Indiana-based Cancer Care Group, P.C., because it did not conduct an enterprise-wide risk analysis and implement follow-on device and media control policies to protect the transportation of unencrypted PHI. OCR contends that a risk assessment could have identified the control weakness.

To assist healthcare entities' readiness for a HIPAA audit, Day Pitney LLP has developed several tools to facilitate compliance with the HIPAA Privacy, Security, and Breach Notification Rules. Information on Day Pitney's compliance tools is available on request.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

See More Popular Content From

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More