Federal regulators have completed work on a document that could terrify as many as a few dozen health insurance agents, brokers and consultants in the coming year: a “pre-audit screening questionnaire.”
The Office for Civil Rights (OCR), an arm of the U.S. Department of Health and Human Services (HHS), is creating the questionnaire in connection with an effort to audit keepers and users of protected health information for compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) health data privacy and data security requirements.
See also: Phase 2 HIPAA audits
OCR officials developed the pre-audit screening questionnaire to help OCR decide whether entities are “eligible candidates for HIPAA compliance audits.”
The entities that get the questionnaires “will provide basic descriptive information about their organization,” OCR officials say in a statement describing the questionnaire. “They will provide information including, but not limited to, a verification of being a covered entity, the type of health care organization, the number of patients, members or transactions, their use of technology, their total revenue per fiscal year and other questions.”
The HIPAA health information rules apply to “covered entities,” such as hospitals and health insurance companies.
The rules also apply to the “business associates” of the covered entities. The “business associate” category can include almost any type of entity that handles protected health information, ranging from accounting firms to medical transcription firms to benefit plan administrators. Most health insurers that sell products such as major medical coverage, Medicare supplement insurance, dental insurance or long-term care insurance require agents to accept responsibility for meeting the business associate requirements.
See also: PwC: Why health data questions drive you crazy
HHS OCR officials have already been auditing the covered entities. OCR officials have been talking about starting to audit the business associates. They have given a little new information about the business associate auditing program in a federal paperwork review packet.