Every year the Office of the Inspector General (OIG) issues a workplan that identifies the agency’s planned audit activities for the upcoming year. The workplan offers valuable information for healthcare entities by providing them with an opportunity to conduct appropriate risk assessments, and, where indicated, to modify the entity’s compliance program.
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New York State Social Service Law §363-d and implementing regulations at 18 NYCRR §521 require that certain healthcare providers adopt and implement an effective compliance program and certify their compliance with the law every December. Last year’s passing of the new HIPAA requirements signaled the government’s concern that individually identifiable health information needs stronger protection beyond the borders of the healthcare industry. HIPAA already recognized this need by imposing obligations on covered entities and their business associates in prior versions of the rule. In the latest rule update, however, the US Department of Health and Human Services, among other things, expanded the definition and responsibilities of business associates and now made them directly liable for HIPAA noncompliance. A new advisory opinion from the Office of the Inspector General (OIG) of the Department of Health and Human Services nixed a proposed arrangement between an independent clinical laboratory and physician groups highlighting the intense scrutiny of lab-physician agreements. |
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