Health Care Law Blog
The Department of Health and Human Services ("DHHS") is moving forward with its HIPAA auditing program, which will launch in late 2011 or in 2012. After the audit protocols have been created, they will be field-tested through approximately 20 audits. Once the field tests are completed, up to 150 on-site audits will take place through the end of 2012. It is not clear which types of entities will be selected for audit. It is also not yet clear whether the DHHS Office for Civil Rights ("OCR") will audit only covered entities, or whether business associates will be audited as well. In addition, the OCR has not yet determined whether or how it will publish its audit results. Given the significance of being subject to a HIPAA audit, organizations should take this time to review their policies and procedures for HIPAA privacy and security compliance. Moreover, with the newness of electronic health record ("EHR") systems, those with EHR will especially want to make sure that these systems are compliant. Please contact me at 517.371.8231 or 906.226.5501 if you would like assistance with any review.
