The Office for Civil Rights had another strong year of investigations and enforcement actions against covered entities. It also has made it abundantly clear that it will not back down from aggressive enforcement into 2016. What’s different this year, is that we will see more investigations and enforcement actions against business associates.
The OCR has publicly announced that its audit program for business associates will start in 2016. I would believe the OCR. Business associates may wish to review their HIPAA compliance programs and shore up that program now before they get that knock at the door.