Mitigating Unauthorized Disclosures of PHI by Employees or Former Employees
The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently submitted two reports to select congressional…
OCR Focusing on Enforcing Patients’ Rights to Access
In a Bloomberg Law article regarding last month’s National Health Insurance Portability and Accountability Act (HIPAA) Summit, reporter James Swann…
New OIG Final Rule Regarding State Medicaid Fraud Control Units
The Department of Health and Human Services (HHS) Office of Inspector General (OIG) has released a final rule to align the regulations…
Developing and Revising Your Organization’s Code of Conduct
The Code of Conduct (Code) should be a statement of an organization’s guiding principles and standards, and it must be…
HHS OIG Proposes Changes to AKS Discount Safe Harbor
In early February, the Department of Health and Human Services (HHS) Office of Inspector General (OIG) proposed amendments to the Anti-Kickback…
Assessing Internal Controls is Critical to Effective Compliance Programs
Compliance Officers are faced with ever-changing laws and regulations and intense scrutiny by regulatory and enforcement agencies. Unfortunately, Compliance Officers…
Tips on Hotline Effectiveness
Employee communication of compliance issues through a hotline is vital to any effective compliance program. The challenge is finding useable…
HIPAA Designated Privacy Officers
Under HIPAA (Health Insurance Portability and Accountability Act of 1996) every HIPAA covered entity must have a designated Privacy Officer.…
Outsourcing the Compliance Officer Function
Overview Although most health care providers have developed a compliance program and appointed a Compliance Officer to manage the program,…
Evidencing Management’s Healthcare Compliance Commitment
Compliance is a top-down program, beginning with members of the executive leadership. At all levels, they must clearly articulate commitment…
How to Properly Select an Independent Review Organization
Overview The Department of Health and Human Services Office of Inspector General (OIG) utilizes many enforcement tools to promote compliance…
Building and Measuring a Culture of Compliance
An organization’s compliance program should set the tone and standards expected in a healthcare work place, especially in terms of…