Anti-Corruption Compliance Program Audits
Creating an Integrated Due Diligence System - Screening to Audits
Keeping Your Due Diligence System Manageable March 31, 2014
Monitoring and Auditing Your Anti Corruption Compliance Program
Benesch B-Cast 07: Immigration Deadlines and Demands Employers Need to Know
Tax Traps of Employment Documents
Building an Integrated Third Party Due Diligence System Initial Screening to Audits
A Price Worth Paying?
An Update on SEF, IDB and Swap Regulation from Chris Ferreri of ICAP
Suzanne Folsom & Christopher Burnham on Private Sector Lessons
Confirmations: Plugging Into Electronic Confirmations
Corporate Law Report: Economic Espionage Act, Top FCPA Enforcement Actions, Trademark Audits, and More
The U.S. Department of Health and Human Services’ Office for Civil Rights (OCR) will soon begin a second phase of audits (Phase 2 Audits) of compliance with Health Insurance Portability and Accountability Act of 1996 (HIPAA)...more
In 2011 the Department of Health and Human Services’ Office for Civil Rights (OCR) established the HIPAA Pilot Audit Program to ensure compliance with HIPAA’s privacy, security and breach notification rules.
Criticism of the RAC (recovery audit contractor) program is becoming a national pastime. Needless to say, hospitals hated the program from the very beginning. And little wonder. The program pays private contractors a...more
A recent settlement from New York—involving the largest fine levied to date in the history of HIPAA enforcement, a staggering $4.8 million imposed on two public hospitals—should remind health care providers, health plans and...more
The U.S. Department of Health and Human Services’ Office for Civil Rights (“OCR”) has notably increased enforcement of compliance with the Health Insurance Portability and Accountability Act (“HIPAA”) and Health Information...more
Beginning in the Fall of 2014, a substantial number of covered entities and business associates will receive a notification and data request from the Health and Human Services' (HHS) Office for Civil Rights (OCR). According...more
The HHS Office for Civil Rights (OCR) recently presented information about the new look of its Phase 2 audit program. The new audits will look little like the old ones, with OCR conducting the audits itself and focusing on...more
Three U.S. Department of Health and Human Services (“HHS”) agencies, the Office for the National Coordinator for Health IT (“ONC”), in conjunction with the Office for Civil Rights (“OCR”) and the Office of the General Counsel...more
In a Feb. 24 notice in the Federal Register, the HHS's Office for Civil Rights (OCR) announced its intention to resume its HIPAA Audit Program. By and large, the audit program has been inactive since December 2012, when OCR...more
The Department of Health and Human Services (HHS) is expected to launch its long-awaited HIPAA audit program sometime in 2014. The audit program will be run by HHS’ Office of Civil Rights (OCR), which is likely eager to get...more
On February 12, 2014, the U.S. Court of Appeals for the Third Circuit held that Federal courts do not have jurisdiction to review HHS’s determination of a “sustained or high level of payment error,” one of two possible...more
Later this year, the Department of Health and Human Services (“DHHS”) is expected to launch its permanent HIPAA Audit Program. The HIPAA Audit Program is authorized under Section 13411 of the HITECH Act, and is designed to...more
The U.S. Government Accountability Office (GAO) recently published the results of a study examining the effectiveness of CMS’s contractors that conduct postpayment claims reviews to identify improper payments (i.e., Medicare...more
Following a detailed study of the manner by which the Centers for Medicare and Medicaid Services (“CMS”) engages in postpayment claims reviews to identify improper payments, the U.S. Government Accountability Office (“GAO”)...more
Proactive self-audits help providers identify potential problems -
The Federal Government is using every tool available to fight health care fraud and recover overpayments from health care providers. According to the...more
Several governmental agencies, including the Internal Revenue Service (IRS), Department of Labor (DOL), Securities and Exchange Commission (SEC) and Department of Health and Human Services (HHS), have stepped up their audit...more
Earlier this week we attended the National Institute of Standards and Technology (NIST) and HHS Office for Civil Rights (OCR) 6th Annual Safeguarding Health Information Conference in Washington, D.C. (the NIST-OCR...more
The government has been increasing its focus on healthcare fraud involving “quality” of care. This is an extremely difficult issue, especially for prosecutors. It is very difficult to define “quality” standards and then...more
The HHS OIG has conducted a nationwide audit of the use and reimbursement of Herceptin (also known as trastuzumab), a Medicare-covered drug used to treat metastatic breast cancer, and has concluded in three audits released in...more
Originally published in Compliance Today on December 1, 2012.
..Covered entities are now subject to privacy and security audits by OCR.
..OCR published audit protocols regarding its standards for such...more
One of the less well-known provisions of the Health Information Technology for Economic and Clinical Health (or "HITECH") Act is the requirement that the U.S. Department of Health and Human Services ("HHS") periodically...more
On June 26, 2012, the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) released on its website the protocol that it has developed to serve as a guideline for recently-implemented HIPAA...more
Protocol provides clues regarding areas of focus for ongoing HIPAA audits assessing compliance with the Privacy, Security, and Breach Notification Rules.
The Office for Civil Rights (OCR) at the Department of Health...more
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