Phase 2 of HIPAA Audits Underway

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The HHS Office for Civil Rights (“OCR”) recently published an announcement describing the next phase of HIPAA audits of covered entities and business associates.  As part of this second phase of the audit program, OCR will be reviewing policies and procedures of covered entities and business associates to determine whether they meet the standards and specifications provided for under HIPAA.  Initially, OCR will seek to verify an entity’s address and contact information through email correspondence.  Based on data collected during this information gathering stage potential audit pools will be identified and subsequent audits will be performed.  This announcement by OCR provides yet another reminder of the importance of assuring that covered entities and business associates have adequate policies and procedures in place to satisfy their respective HIPAA compliance obligations.

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Paul J. Welk

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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