It is ironic to learn the Office of Inspector General (OIG) believes the Office of the National Coordinator for Health Information Technology (ONC) essentially has an insufficient compliance program to maintain the privacy and security of the protected health information (PHI) hosted by electronic health records (EHR).
In an August 2014 report (A-06-11-00063), OIG concluded…
Perhaps not coincidentally, immediately following the release of the Questionable Laboratory Payments Special Fraud Alert by the OIG, posted yesterday on the Med Law Blog, the OIG has followed up with Audit Report OIG – 03-11-00730: Questionable Billing for Medicare Part B Clinical Laboratory Services. Below are two quoted paragraphs from the executive…
There has been significantly enhanced scrutiny of financial relationships between referring physicians by both the Office of Inspector General (OIG) and Pennsylvania authorities.
Pennsylvania
Pennsylvania enacted amendments to the Pennsylvania Clinical Laboratory Act on December 18, 2013 (the amendments are referred to as Act 122) and the Department of Health and Bureau of Laboratories just…
|
…
U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently announced yet another enforcement action. Specifically, OCR opened a compliance review of Concentra Health Services (Concentra) upon receiving a report that an unencrypted laptop was stolen from the Springfield Missouri Physical Therapy Center. The investigation revealed that Concentra had previously recognized…
A HIPAA security risk assessment (SRA) tool was recently made available through HHS. The tool was developed as a collaborative effort between the HHS Office of the National Coordinator for Health Information Technology (ONC), the HHS Office of Civil Rights (OCR) and the HHS Office of General Counsel (OGC). This SRA tool is intended to…
OCR PREPARING FOR NEXT ROUND OF HIPAA AUDITS
In a February 24, 2014 notice published in the Federal Register, the Department of Health and Human Services announced a pre-audit survey of HIPAA covered entities and business associates. The information collected will involve a survey of up to 1,200 covered…
Microsoft recently announced that, after April 8, 2014, it will not longer provide security updates or technical support for Windows XP. Microsoft’s statement that “businesses that are governed by regulatory obligations such as HIPAA may find that they are no longer able to satisfy compliance requirements” has spurred a certain level of panic among health…
Attorneys routinely advise clients conducting audits and investigations that the audit or investigation should be conducted by outside counsel in order to establish attorney client privilege.
One of the problems with the OIG Self Disclosure protocol is that it requires the waiver of attorney client privilege. Now a federal district court has decided that audits …
The 2014 OIG Work Plan includes the following:
Billing and Payments. We will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A (for example, stays during which benefits are exhausted or the 3-day prior-inpatient-stay requirement is not
…
