As Phase 2 of the HIPAA audit program begins, covered entities (CE) and business associates (BA) will be watching their email for an audit letter from OCR. Of those chosen for audit, most will be selected for a desk audit. They'll have 10 days after receipt of the email to gather requested documents for OCR's auditors.
But how will CEs and BAs know they are collecting the right information? A careful reading of the updated Phase 2 audit protocol (www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/protocol/index.html) will help guide CEs and BAs. But if the protocol isn't read carefully, and in full, important documents could easily be left out, leading to inaccurate audit reports and even a visit from OCR's investigators.
The Phase 2 audit protocol expands the Phase 1 compliance areas to reflect changes made by the 2013 HIPAA omnibus final rule. The updated audit protocol also includes information for BAs, which were not audited during Phase 1 but will be in the current round of audits. The protocol contains a description of the audit areas, general instructions and definitions, and a keyword-searchable table.
Phase 2 audits will be conducted in three rounds. The first two rounds will consist of desk audits of specific audit targets, while the third round will be comprehensive audits. Round one audits will target CEs and round two audits will target BAs.
Editor's note: This is part one of a series about medical identity theft. Look for part two in an upcoming issue of BOH.
Privacy and security officers are sitting on a hoard of valuable data: medical identity information. Social Security numbers. Medicare, Medicaid, and other insurer numbers. Credit card and bank account information. This data can fetch a high price on the black market, and medical identity theft costs patients, providers, and insurers millions of dollars a year. The lure of medical identity information makes healthcare organizations an appealing target for criminals, from large operations launching sophisticated hacking schemes to smaller groups running tried and true fraud scams.
A 2015 study conducted by the Ponemon Institute and sponsored by the Medical Identity Fraud Alliance (MIFA), the Fifth Annual Study on Medical Identity Theft, found that medical identity fraud nearly doubled between 2010 and 2014. More than 2.3 million adults were victims of medical identity theft and fraud in 2014 alone. The average cost per victim was $13,500 and the combined out-of-pocket cost was approximately $20 billion. But the financial impact is only the tip of the iceberg. Medical identity theft can result in physical harm to a patient if the medical record is altered to include another person's information such as allergies, disease status, or blood type.
Healthcare organizations often absorb some of the costs, and if the stolen PHI was used to commit Medicare or Medicaid fraud, they could be investigated by the OIG.
The stakes are high but by raising awareness and championing education and robust security programs, privacy and security officers can help their organizations stay one step ahead of criminals.
When compared to data from past surveys, HCPro's 2016 HIM director and manager salary survey revealed a harsh truth that many HIM professionals already know: There has been little movement in HIM manager and director salaries over the years.
Anatomical modifiers qualify a HCPCS/CPT® code by defining where on the body the service was provided. These modifiers are especially helpful to indicate services that would normally be considered bundled but were actually performed on different body sites.
Congressional legislation is often written in a way that obfuscates or, at the very least, makes it difficult to discern the impact or intent of a bill.
Q: We operate a partial hospitalization program (PHP) and just heard from our billing office that there are new requirements for submitting claims. They want us to close out accounts weekly in order for them to bill them. We have done 30-day accounts prior to this and don’t see why they want to change things. Is there a certain timeframe required for billing these services? This is a huge inconvenience to make this work for the business office.
