You can’t run and you can’t hide — HIPAA audits are coming. HHS, through the Office of Civil Rights (OCR) recently named KPMG as the recipient of a $9.2 million contract to develop a HIPAA auditing protocol and conduct audits on 150 covered entities and business associates before December 31, 2012. An additional $180,000 contract has been awarded to Booze Allen Hamilton for “OCR HIPAA Audit Candidate Identification.” If they identify you, are you prepared?

Section 13411 of the Health Information Technology for Economic and Clinical Health (HITECH) Act (passed as part of the American Recovery and Reinvestment Act of 2009), required HHS to conduct periodic audits of providers and business associates to ensure their compliance with “this subtitle and subparts C and E of part 164 of title 45, Code of Federal Regulations, as such provisions are in effect as of the date of” the HITECH Act. The HITECH Act itself provides no explanation of what an audit might entail, but the OCR solicitation itself provides some details. According to the solicitation, required audit work will include a site visit, including...