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Health Care Communiqué: 2Q - 2010
Public Disclosure of HIPAA Breaches
A new HIPAA requirement contained in the Health Information Technology for Economic and Clinical Health (HITECH) portion of the American Recovery and Reinvestment Act of 2009 (ARRA) called for breaches of unsecured protected health information (PHI) to be reported to the Office of Civil Rights (OCR).
That reporting began during late September 2009 and now, with seven months of information, we can begin to see some patterns from the publicly posted breaches. OCR posts reported breaches of unsecured PHI that impacts 500 or more individuals, on their web site (http://www.hhs.gov/ocr/privacy/hipaa/administrative/breachnotificationrule/).
During the first seven months of reporting, 93 breaches have been posted which in total impacted over an estimated 2.6 million people. In addition to the breaches that impact 500 or more individuals OCR has stated that they have received over 6,000 breach reports in total.
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CMS Audit, Part 4: Managing the Site Visit
A critical part of any CMS audit is the site visit. For a full audit CMS might send as many as five reviewers to be onsite for up to four days. The number of reviewers and amount of time depends on the audit scope. The reviewers are often a mix of CMS staff and contractors. Some parts of the audit may be completed by offsite reviewers. For example, this is often done if the review includes audit elements related to fiscal issues. In addition CMS has outsourced parts of the review (e.g., quality improvement programs) to vendors.
The site visit begins with an entrance conference. This is an opportunity for introductions between the CMS reviewers and the health plan staff. Health plan attendees should include the Medicare Compliance Officer, key executives and management involved in the audit and if available a representative from the Board of Directors. The health plan will be given an opportunity to present an overview of the current organization and operation. This should be concise and focused as you will want to give the reviewers some context, but in general they are interested in moving on to the actual audit and completing their reviews/spreadsheets.
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Medicare Library Updated in 2010
Throughout 2010, Kaplan EduNeering has been consolidating our Medicare Advantage library, releasing new courses that are focused on topics that previously spanned two or more courses. The new courses also feature new graphics and eye-catching styles, with the goal to engage learning while reducing the time needed to grasp the regulatory content.
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