The Office of Civil Rights (“OCR”) of the U.S. Department of Health and Human Services (“HHS”) is preparing to resume its Health Insurance Portability and Accountability Act (“HIPAA”) compliance audit program. In a notice published in the February 24, 2014 Federal Register, OCR announced its plans to conduct a pre-audit survey of up to 1,200 organizations. The purpose of this pre-audit survey is to gather information about survey respondents to enable OCR to identify candidates for audit under the OCR HIPAA Audit Program. HHS is accepting comments regarding the pre-audit survey until April 25, 2014.
The OCR Pilot Audit Program concluded in December 2012. Since the Pilot Audit Program ended, OCR has been working on the development of protocol for the permanent HIPAA Audit Program. The Pilot Audit Program evaluated 115 HIPAA covered entities (health plans, health care providers and health care clearinghouses). This time around, OCR is selecting both covered entities and business associates for audit. While the precise audit schedule has not been released, the pre-audit survey will serve as an initial step toward finalizing audit plans for 2014.