The second Tuesday of each month, practice managers and healthcare industry service providers gather at KraftCPA headquarters for the monthly Nashville Medical Group Management Association (NMGMA) meeting.
During the September luncheon, Christopher Lyons, HCISPP, a consultant with managed security services company Sword & Shield Enterprise Security, discussed the HHS Office for Civil Rights (OCR) random audit program. In July, OCR notified 167 covered entities of their 'selection' to participate in HIPAA desk audits. Lyons said a similar selection process was slated to occur for business associates at the end of September.
He noted the desktop audits are limited to a subset of the Security, Privacy and Breach Notification rules. However, onsite audits, which resume in 2017, will evaluate against the comprehensive set of HIPAA compliance controls. Desk audits do have the potential to turn into onsite audits.
A couple of points to remember, Lyons said, is that OCR will not accept policies and procedures in a paper format so everything must be made available electronically. While full compliance is expected, Lyons added those being audited should "provide only what is requested."
One major tripping point that plagues many covered entities is privacy notifications. "Do you have privacy rules notices hanging on the walls in addition to handing them out in person?" Lyons asked the group. "And," he continued, "It must be posted conspicuously on walls wherever patients come in." Therefore, if there is a front and back entrance to the office, the notification must be hanging in both places. The policy has to be posted on the website, as well.
While it might seem like common sense, Lyons said the best advice is to curb visible annoyance at the amount of extra work an audit entails. Sarcasm, he noted, doesn't typically don't go over well. "Auditors hold your fate in their hand. They are human ... be nice," he counseled with a grin.
For more information on the OCR audits, go online to: hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/index.html. There are a multiple resource links under the Phase 2 Audit heading.
The next NMGMA meeting is scheduled for October 11. For reservations or to learn more about the association, go online to nmgma.site-ym.com.