Posted by Dr. Don Cross on July 06, 2016
Growing up I was one of those kids who was always asking, “Why?”
My parents would sometimes lose their patience and reply back “Because I told you to!”
Today I sometimes get that same “why” question from doctors who are frustrated with all the new government regulations. This time I must answer, “Because HHS said too.”
Now with the release of the Office of Civil Rights audit protocol for HIPAA Phase II audits, I can simply show them what the auditors are going to be asking for when they perform their desk audits. The OCR has released the protocols so that we can prepare in advance.
One of the common aspects requested is, and I quote, “Do the policies and procedures provide for the treatment of an…” and “Obtain and review policies and procedures for the…”
All throughout the protocol are repeated directions for the auditors to obtain and review the facility’s policies and procedures. (Checkout the link to the OCR website and the audit protocol for yourself.)
As I tell my Palmer students on a regular basis, “Your policies and procedures are your best protection.”
A word of caution, having a good policy and procedure manual is not enough. You must follow your policies and procedures and be able to demonstrate your compliance through the appropriate documentation (the Chiropractic Compliance set has a method to keep you on track).
The auditors are directed to ask for the supporting documentation. They then will determine if you are meeting the specific standards that have been established. So why do we need policies and procedures, “Because the Fed’s said to!”
Don M. Cross, DC
Certified Professional Compliance Officer
We offer a step-by-step process to get your practice compliant, including manuals, forms, training and audit logs.
Get the OCCM Chiropractic Compliance Set today.