With the HHS Office for Civil Rights expected to begin random HIPAA audits in 2015, covered entities should take another look at the expanded penalties for privacy and security violations under the updated HIPAA Omnibus rule that went into effect in September 2013.

Of particular concern is the issue of audited or investigated organizations having done little or nothing to become HIPAA compliant, such as failing to be able to produce policies and procedures that govern a compliance program, or not being aware of the need for compliance. “On this point, ignorance is not bliss,” said Lorretta Duncan, senior medical practice consultant at liability insurer Volunteer Mutual Insurance Co., during a presentation at the MGMA Annual Convention in Las Vegas.

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