OCR Preparing For Next Round Of HIPAA Audits

OCR Preparing For Next Round Of HIPAA Audits

In Physical Therapy Articles by Paul J. WelkLeave a Comment

In a February 24, 2014 notice published in the Federal Register, the Department of Health and Human Services announced a pre-audit survey of HIPAA covered entities and business associates.  The information collected will involve a survey of up to 1,200 covered entities and business associates to determine suitability for an Office of Civil Rights (OCR) HIPAA audit program.  The survey will collect information related to the size, complexity, number of patient visits, revenue, and business locations of health care providers.  This second round of HIPAA audits, a follow up to the pilot audit program that OCR established in 2012, is based upon the mandate that OCR conduct periodic audits to assess compliance with the HIPAA Privacy, Security and Breach Notification Rules.

For those covered entities and business associates that have been less than diligent in satisfying their HIPAA compliance requirements, this notice is but another reminder that OCR continues to step up its proactive enforcement efforts to identify, and take action against, non-compliant entities.

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Paul J. Welk

Paul is chair of Tucker Arensberg Attorneys Health Law/Health Information Technology Industry Group and focuses his practice on corporate and healthcare law. In this capacity, he represents physical therapists, physicians, dentists, not-for-profit organizations, professional organizations and other business corporations and entities.

Some of the recent transactions and clients he has worked on include the representation of:

  • Multiple state physical therapy professional associations on a variety of issues
  • Multiple physical therapy private practices with development and implementation of ownership succession plans
  • A venture capital company with the $13 million dollar stock acquisition of a target company
  • Multiple physical therapy providers in successful third party payer appeals
  • Multiple buyers of the assets and associated real estate of dental practices
  • Multiple physical therapy providers regarding the transfer of partial ownership interests and the negotiation of governance and shareholder documents
  • Multiple physical therapy providers with asset and stock acquisitions and divestitures
  • A manufacturing company with the successful negotiation of a shareholder dispute and stock purchase
  • A service provider with negotiation of a $5 million annual service contract
  • A publicly traded company regarding the merger of two wholly owned subsidiaries
  • Two publicly traded companies regarding the ongoing review of distribution, supply and service contracts
  • A seller of a skilled nursing facility and related real estate
  • Multiple regional rehabilitation provider networks on a variety of issues, including formation and ongoing operations
  • A large physician practice in its sale to a health system

Areas of Practice: Business and corporate law, health law, mergers and acquisitions

Articles and Presentations: Paul regularly lectures and writes on topics related to business and healthcare law and is the founding author of Legal Impact, a regular column in the American Physical Therapy Association Private Practice Section’s Impact Magazine.

Memberships and Activities: Paul is a member of the American and Pennsylvania Physical Therapy Associations and past Chair of the American Physical Therapy Association Committee on Risk Management and Member Benefits. He is also a member of the Bloomsburg Medical Supply Ethics Committee, the Duquesne University School of Physical Therapy Advisory Board, the Pennsylvania Bar Association, and the American Health Lawyers Association. He is an adjunct instructor at the St. Francis University School of Physical Therapy and a licensed physical therapist in the Commonwealth of Pennsylvania.

Jurisdictions: Paul is licensed to practice law in Pennsylvania.

Education and Background: Paul received his Bachelor of Science and Master of Physical Therapy degrees with honors from Duquesne University and his law degree with honors from the University of Pittsburgh. He served as associate editor of the University Of Pittsburgh School Of Law Journal of Law and Commerce and received the CALI Excellence for the Future and Esther F. Teplitz Awards for academic performance in the health law curriculum. Paul is a graduate of the University Of Pittsburgh School Of Law’s Health Law Certificate Program.

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