On March 6, 2014, the U.S. Department of Health and Human Services, Office for Civil Rights (“OCR”) reached a $215,000 settlement with Skagit County in northwest Washington state for violations of the HIPAA Privacy, Security and Breach Notification … [Continue reading]
Meaningful Use Exception Includes EHR Vendor Delays
March 11, 2014 By
Following its announcement at HIMSS, CMS has published its hardship exception application for 2014 along with its new exception due to vendor delays. The new exception permits eligible hospitals and eligible professionals to request an exception … [Continue reading]
Increased OIG Focus on Kwashiorkor Claims
March 10, 2014 By
In its recently released 2014 Work Plan, the OIG has announced that it will investigate hospital billing for Kwashiorkor. Kwashiorkor is a form of severe protein malnutrition that generally affects children living in tropical and subtropical parts … [Continue reading]
Upcoming HIPAA Audits Will Include Business Associates
March 5, 2014 By
On February 24, 2014, the Department of Health and Human Services (“HHS”) published a notice of its proposed collection of information in connection with its HIPAA audit efforts. Comments on the proposed collection request must be submitted by April … [Continue reading]
2014 OIG Work Plan Contains New Priorities Specific to Hospitals
February 27, 2014 By
The Department of Health and Human Services, Office of the Inspector General (OIG) recently released its Fiscal Year (FY) 2014 Work Plan. The Plan contains new priorities specific to Hospitals in areas related to Policies and Practices, Billing and … [Continue reading]
The Business Associate Agreement Battle – Understand the Key Issues
February 26, 2014 By
The September 2014 deadline for amending pre-existing HIPAA business associate agreements (BAA) is fast approaching. Are you ready? Under the HITECH Act, covered entities and business associates have just under seven months to negotiate and … [Continue reading]
Key Lessons Related to Stark Compliant EHR Donation Arrangements
February 26, 2014 By
Is your entity thinking about engaging in a Stark/AKS Compliant EHR Donation Arrangement? If so, check out this list of top 5 issues to consider as you are assessing your options and your health IT alignment strategy. 1. An EHR donation … [Continue reading]
Understanding Stark/Anti-Kickback Compliant EHR Donation Arrangements
February 25, 2014 By
In 2006 and extended in December 2013, CMS issued Stark and Anti-Kickback exceptions/safe harbors permitting EHR technology donation arrangements between hospitals (and other organizations) and physician groups. This exception permitted hospitals to … [Continue reading]
High Number of HIPAA Mobile Device Breaches – Time to Use Safe Harbor Encryption
February 24, 2014 By
Most breaches of electronic protected health information (ePHI) reported to the Department of Health and Human Services (HHS) have related to the theft or loss of unencrypted mobile devices. These breaches can lead to potentially hefty civil fines, … [Continue reading]
HHS Issues HIPAA Guidance For Mental Health
February 21, 2014 By
HHS recently issued HIPAA guidance for mental health practitioners, in an effort to help providers wade through complicated decisions of when disclosures of patient information are permissible. This guidance, set up in a FAQ format, is designed to … [Continue reading]
