Day Pitney recently announced the launch of its HIPAA Self-Assessment Tool to help clients prepare for the second phase of HIPAA audits by the Department of Health and Human Services' Office for Civil Rights (OCR) in early 2016. The target for these audits has expanded beyond covered entities—healthcare providers, health plans, and clearinghouses—and will also include business associates, such as vendors, suppliers, and consultants.

Because HIPAA non-compliance can be costly and disruptive to an organization, Day Pitney created a simple-to-use automated tool based on OCR’s audit protocol to help clients assess whether they are in compliance with HIPAA’s security, privacy and breach notification requirements. OCR has engaged a contracted vendor to conduct the audits and OCR has the authority to initiate enforcement actions based on  the audit results.

“Companies should really start self-audits as soon as possible to make sure they are in compliance with the HIPAA rules,” said James Bowers, Day Pitney director of compliance risk services and former chief compliance officer at Aetna. “The most common deficiency found by the OCR is  the failure to conduct a security risk assessment to identify and mitigate risks to Protected Health Information that may be exposed on servers and unencrypted laptops, as well as ancillary risks resulting from unchanged default passwords, outdated security software and inadequate training.”

The tool is designed to be completed by a company’s compliance officer, privacy officer, health information manager, medical records manager or legal counsel. Although the tool cannot guarantee a successful audit result, any covered entity or business associate can benefit from its use. Even organizations that have done a lot of work to implement the necessary privacy and security policies can use the tool to uncover potential gaps in their compliance program.

For organizations that have not yet completed their HIPAA-readiness, the tool can be used as a roadmap that shows what needs to be done. “Once a client inputs its information, the Tool provides an automated assessment summary,” said Day Pitney healthcare attorney Susan Huntington. “If there are areas of non-compliance, our team is ready to work with the client to address and correct such areas. ”

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