The Phase 2 HIPAA Audits Are Here: Be Prepared with the Knowledge and Tools to Respond
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Are you prepared for Phase 2 HIPAA Audits? Learn what to expect and how to successfully navigate the audit process.The Office of Civil Rights (OCR) within the U.S. Department of Health and Human Services completed Phase 1 HIPAA audits on a sample size of covered entities in 2011 and 2012. By all accounts, the results of the Phase 1 audits revealed a number of areas where a large percentage of covered entities are not in compliance, including a lack of thorough risk analysis and failure to comply with breach notification rules. After reviewing the data and conducting surveys of the audit participants, OCR is now starting the process of conducting more narrowly tailored Phase II audits on a larger number of covered entities and their business associates. Understandably, the Phase 2 audits will focus on areas of noncompliance revealed by Phase1, and the greater risk to the security of Protected Health Information (PHI) confirmed by Phase 1's findings and observations. The Phase 2 Audit process is just starting, and there are still things you can do to ensure that your organization is prepared. This topic will assist in that preparation by (i) providing the necessary context to allow your organization to focus on the issues most likely to be addressed by auditors; (ii) educating you on Phase 2's processes and protocols; and (iii) providing both legal and practical tools and advice to successfully navigate the audit process and minimize the risks of noncompliance.
Daniel E. Rohner, Shook, Hardy & Bacon L.L.P.
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