News & Analysis as of September 22, 2024

HIPAA Audits

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Business Associates can refer broadly to individuals engaged in business relationships with one another. However, in the HIPAA context, the term has a specific statutory meaning and those characterized as business associates have expanded data protection obligations and duties. Essentially, a business associate under HIPAA is a person or entity that performs certain functions or services which necessitates exposure to protected health information on behalf of a covered entity. Typical business associate functions include: claims processing or administration, data analysis, billing, etc. less -

OCR Identifies Continuing HIPAA Enforcement Issues, Areas of Future Guidance and Regulations

Mintz - Health Care Viewpoints on 4/4/2017

Last week the Health Care Compliance Association hosted its annual “Compliance Institute.” Iliana Peters, HHS Office for Civil Rights’ Senior Advisor for HIPAA Compliance and Enforcement, provided a thorough update of HIPAA...more

HHS Expected to Release Significant HIPAA Privacy Guidance This Year; Compliance Audits Proceed; Guide on Compliance Program...

WilmerHale on 3/30/2017

HIPAA privacy guidance, audits, and enforcement are continuing under the new Administration. On March 27, 2017, Iliana Peters, Senior Adviser for HIPAA Compliance and Enforcement at the US Department of Health and...more

OCR Alerts Listservs About Fake Phishing Email to Covered Entities and Business Associates

Robinson+Cole Data Privacy + Security Insider on 12/2/2016

On November 28, 2016, the Office for Civil Rights (OCR) issued an Alert to its listservs that a phishing email is being circulated on “mock HHS Departmental letterhead under the signature of OCR”s Director, Jocelyn Samuels”...more

More on HIPAA Audits for 2016 and 2017–Desk Audits and On-Site Audits

Foley Hoag LLP - Security, Privacy and the... on 11/28/2016

As part of the ongoing HHS OCR HIPAA audit initiative, it is conducting “HIPAA desk audits.” These audits don’t involve auditors coming in your facility. Instead, covered entities are being asked to submit documents on...more

Just Around the Corner – HIPAA Audits for Business Associates

Davis Wright Tremaine LLP on 10/19/2016

Financial organizations that are business associates can expect a wave of HIPAA desk audits to evaluate the HIPAA compliance efforts of business associates. These audits have a limited focus and are conducted by the U.S....more

HIPAA Security Rule Compliance for Providers & Business Associates in Three Easy Steps

Buchalter on 8/24/2016

On August 4, 2016, the Office for Civil Rights (“OCR”) of the U.S. Health & Human Services Department (“HHS”) announced a $5.55 million HIPAA settlement with Advocate Health Care Network (“Advocate”), the largest...more

HIPAA Phase 2 Audits: What Has OCR Requested from Auditees to Date?

Alston & Bird on 8/24/2016

In our April 8, 2016, advisory, we discussed the U.S. Department of Health and Human Services’ (HHS) Office of Civil Rights (OCR) “Phase 2” audit program. Then, we could only make educated guesses about what documents OCR...more

HIPAA News: HHS Getting Tough On ePHI Data Breaches

Snell & Wilmer on 8/8/2016

On August 4, 2016, the U.S. Department of Health and Human Services, Office of Civil Rights (OCR) announced a record-setting settlement with Advocate Health Care Network (Advocate) for multiple potential violations of HIPAA...more

Regulatory Authorities Launch The Second Phase Of The HIPAA Compliance Audit Program

Laner Muchin, Ltd. on 7/20/2016

As a part of its continued efforts to assess compliance with the Health Insurance Portability and Accountability Act (HIPAA) Privacy, Security, and Breach Notification Rules, the Health and Human Services (HHS) Office for...more

The Long Anticipated HIPAA Audits Are Here!

Miller & Martin PLLC on 7/20/2016

Phase 2 HIPAA Audits, which the Department of Health and Human Services' Office of Civil Rights ("OCR") announced had "launched" back in March of this year, have now officially begun. On Monday, July 11, 2016, the first round...more

OCR Begins HIPAA Phase 2 Audits

Morgan Lewis on 7/19/2016

What covered entities and business associates can do to prepare for the next round of audits. On July 11, the HIPAA Phase 2 audits commenced when 167 covered entities received notice of a desk audit from the Department...more

HHS Releases HIPAA Privacy and Security Audit Guidelines as it Starts its Second Round of Audits and Continues Enforcement Efforts

Winstead PC on 6/3/2016

During April 2016 the Department of Health and Human Services (“HHS”) posted lengthy audit guidelines for HIPAA Privacy and Security on its website (over 400 pages). As HHS starts its audits of health care providers, health...more

Coming Soon to Your Inbox! Phase 2 of OCR's Audit Program for HIPAA Compliance

Poyner Spruill LLP on 5/23/2016

On March 21, 2016, the Office of Civil Rights (OCR) in the Department of Health and Human Services (HHS) announced that it was ready to begin Phase 2 of its audit program for HIPAA compliance, which will include auditing...more

The Audit Protocol is Released, and Other Updated HIPAA Audits News

Davis Wright Tremaine LLP on 4/12/2016

As we previously reported, the HHS Office for Civil Rights (OCR) launched Phase II of its audit program on March 21. Since that time, a significant amount of new information has emerged, including details regarding the...more

Employee Benefits & Executive Compensation Advisory: So You Heard About HIPAA Phase 2 Audits. What Should You Do Now?

Alston & Bird on 4/11/2016

As you may have recently read (for example, “HHS/OCR Announces Launch of HIPAA Audit Program Phase 2”), the U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) has started “Phase 2” of its audit...more

How Recent Cybersecurity Government Publications Impact HIPAA Security Compliance and the New Audit Initiative

Winstead PC on 4/7/2016

Cybersecurity Impacts on HIPAA Security Compliance and the New Audit Initiative - New Audit Initiative Items to Watch - While The HHS Office for Civil Rights recently announced its intent to perform a second...more

Phase 2 of HIPAA Audit Program Launched

Clark Hill PLC on 4/6/2016

The U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) announced on March 21, 2016 that it has officially launched Phase 2 of its Health Insurance Portability and Accountability Act...more

HHS OCR Announces Launch Of Long-Awaited Phase 2 HIPAA Audit Program

King & Spalding on 4/4/2016

On March 21, 2016, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced the launch of its Phase 2 HIPAA compliance audits pursuant to which it will audit covered entities and...more

HHS Implements HIPAA Phase II Audit Program: What You Need to Know

Hinshaw & Culbertson LLP on 3/29/2016

Recently, the Health and Human Services Office of Civil Rights announced that it has implemented its HIPAA Phase II Audit Program. Some entities may have already received initial emails from the Office of Civil Rights (OCR)...more

HHS OCR Launches Phase 2 of HIPAA Audit Program–So What?

Foley Hoag LLP - Security, Privacy and the... on 3/26/2016

You have seen all the hysterical headlines — “The HIPAA audits are coming, the HIPAA audits are coming….” But when you really think about it, what is the big deal? If you are a HIPAA covered entity, you surely know by now...more

OCR Launches Phase 2 of HIPAA Audits

Morgan Lewis on 3/25/2016

Five suggested steps healthcare organizations and their contractors should take to prepare. On March 21, the Office of Civil Rights (OCR) of the Department of Health and Human Services launched Phase 2 of the HIPAA Audit...more

Ready or Not, It’s Time For Phase 2 HIPAA Audits

Mintz - Health Care Viewpoints on 3/22/2016

On March 21st, the HHS Office for Civil Rights (“OCR”) officially launched Phase 2 of the HIPAA Audit Program. Covered Entities and Business Associates need to be prepared for these audits and be on the lookout for emails...more

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