[authors: M. Daria Niewenhous and Dianne J. Bourque]
Last week at the OCR/NIST conference, Building Assurance through HIPAA Security, Linda Sanches of the Office for Civil Rights provided an extensive update on the pilot HITECH audit program, including preliminary findings, what regulated entities can expect next and suggestions for covered entities concerned about being audited. Mintz Levin attended the conference and is pleased to share some of the highlights below:
The initial round of audits included 8 health plans, 10 providers, and 2 clearinghouses.
OCR’s general advice for covered entities was to conduct regular program reviews and updates. Covered entities were advised to look at their compliance programs, re-evaluate and make necessary updates on a regular basis. According to OCR, ongoing policy review and revision is a compliance requirement.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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