With the start of 2016 in sight, those of us in compliance need to make sure we are ready for phase two of the audits as they will start in early 2016. The Offices of Health and Human Services of the Inspector General (OIG) conducted a study to look at the Office of Civil Rights (OCR) and their oversight of the audits and concluded OCR needed to strengthen their oversight.
They recommended the following:
(1) fully implement a permanent audit program;
(2) maintain complete documentation of corrective action;
(3) develop an efficient method in its case-tracking system to search for and track covered entities;
(4) develop a policy requiring OCR staff to check whether covered entities have been previously investigated; and
(5) continue to expand outreach and education efforts to covered entities. OCR concurred with all five recommendations and described its activities to address them.
The OCR agreed with the recommendations and is working on a permanent audit program. They are also saying they will concentrate on areas of high risk and non-compliance that were found in phase one audits. As we have heard previously, both covered entities as well as business associates will be audited.
OCR is also looking into ways to better track corrective actions identified in audits previously performed.
As we go into 2016 it may be a great time to check all those policies and procedures and make sure that you have all the documentation in place. For more information visit http://oig.hhs.gov/oei/reports/oei-09-10-00510.pdf
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