The U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) is continuing its efforts to enforce HIPAA compliance through periodic and proactive audit programs. These audits are designed to assess how well Covered Entities and Business Associates are meeting their obligations under the HIPAA privacy, security, and breach notification standards.
With audit activity resuming and expanding, organizations should not wait to prepare. Now is the time to strengthen your compliance program, identify gaps, and ensure you’re meeting regulatory requirements.
Who Is Subject to HIPAA Audits?
OCR audits target both Covered Entities and their Business Associates, which include:
- Health plans of all types
- Healthcare providers (individual and organizational)
- Healthcare clearing houses
- Health information organizations
- E-prescribing gateways
- Personal health record vendors
- Data transmission service providers that require routine access to PHI
If you’re a Business Associate working with a high-profile or high-risk entity, there’s a high chance of being included in an audit and a visit from the OCR.
Key Areas of Focus in HIPAA Audit Programs
HIPAA audits are comprehensive and typically focus on high-risk areas where past violations have been common. These include:
- Security Risk Analysis and Risk Management
- Breach Notification Content and Timeliness
- Privacy Notices and Access to Medical Records
- Training and Implementation of Policies and Procedures
- Device and Media Controls, Transmission Security
- Encryption, Decryption and Physical Access Controls
Organizations are expected to demonstrate not only that policies exist, but that they are actively implemented, enforced, and regularly reviewed. Use this time to find gaps in your policies and procedures and start remediating from there.
Steps to Take Now to Prepare for a HIPAA Audit
Do you have someone overseeing your compliance efforts? Proactive preparation is critical. Here are the steps every organization should take:
- Conduct a risk assessment to identify vulnerabilities
- Review and update policies and procedures in line with current HIPAA and Omnibus Rule requirements
- Deliver comprehensive HIPAA training to all workforce members
- Ensure technical, physical, and administrative safeguards are in place and functioning
- Review Business Associate agreements and ensure all vendors meet compliance standards. Compliance must be more than a checkbox—it should be a priority and part of your organizational culture, starting with leadership and extending to every employee.
Don’t Wait for an Audit Notice
OCR audits can be triggered at any time, and failing to demonstrate compliance can result in consequences, including fines or reputational damage. The best defense? A well-documented, consistently applied HIPAA compliance program.
If you need expert help navigating HIPAA audit requirements, contact us today to get started and stay audit-ready.