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 would likely request from auditees. However, on July 11, 2016, OCR contacted the covered entities it selected. Although the tight 10-day turnaround caused some angst for those audited, the scope of OCR’s requests (drawn directly from the OCR audit protocol document) was less onerous than many predicted (especially given the length of the protocol document).
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