What to Expect When the HIPAA Auditors Arrive?

You think it’s an average, ordinary day and sit back as you go through the mail.  You pull an envelope out of the pile, read the return address and suddenly sit up straight.  You already know the contents of what is inside and your heart rate increases as you carefully slit open the top.  Despite telling yourself you could be wrong as you remove the letter, you discover  you are not.  It is the dreaded OCR audit notification letter.  Cue the panic.

When this letter arrives, there’s no need to hear the theme from “Jaws” in you head.  If you ensure you have made a good faith effort to comply with the HIPAA / HITECH requirements based on the final Omnibus rule, and have documented this as policy mandates, you can breath easier, and when the audit occurs you will not feel as if you are in shark infested waters.

Read More

CMS Meaningful Use Audits are coming are you ready?

CMS has started audits on organizations that have attested to HITECH Meaningful Use and have received funds.  They plan is to audit 5 % percent of the people who have attested for HITECH Meaningful Use core measure 15 and received funding.  Although the initial audit is a “Desk Audit” done electronically where a third party company will be requesting electronic documentation on your attestation, your lack of documentation or performance could lead to them reporting you to HHS as a HIPAA Violator.  If you are found to be negligent you could face fraud enforcement charges if your documentation does not meet the guidelines.  Some sites have been already moved to this process while others have appealed. 

These audits involve the HIPAA Risk Assessment and EHR compliance.  So the question to yourself should be, have you completed a HIPAA Security Risk Assessment (Audit and Remediation) and do you have the ability to regurgitate that information to auditors in the event you are audited or accessed that would include the Gap and Remediation plans, and possibly your HIPAA policy and procedures.

If not prepare be prepared for lawyers, fines and possibly and fraud investigation.

Read More