All posts tagged Human Resources

Measuring program value, or return on investment, is critical and imperative in managing a healthy wellness program. Further, clearly identifying and objectively evaluating the impact helps keep the vendor focused on what is critical for the employer. If these programs are not having the impact intended, then the cost of those services is only adding to medical spending waste.

When adding wellness services to any employer benefits package, it is imperative to clearly identify the intended impact and outcome. Outcomes fall into three general categories:

  1. Employee satisfaction with the employer, which adds to recruitment and retention
  2. Reducing biometric risk and improving the health of the population
  3. Reducing medical spending

Employee Satisfaction

In the book, Shared Values, Shared Results by Dee W. Eddington, Ph.D., and Jennifer S. Pitts, Ph.D., the value of employees appreciating the benefits an employer offers is clearly outlined as a win-win strategy. If an employer’s intent in providing wellness services is to improve the support for its employees, then measuring the satisfaction related to those outcomes is critical. Employee surveys are typically the best approach to gather outcomes related to these intended programs. Some key questions to ask may include:

  • Is working at this organization beneficial for my health? (“Strongly Agree” to “Disagree” responses)
  • Do I trust that my organization cares about me? (“Strongly Agree” to “Disagree” responses)
  • Which of the following wellness program initiatives do you find to be valuable? (list all programs offered)

Collecting employee, or spouse, feedback on these programs will provide insight to allow an employer/ consultant to know if programs are appreciated, or if modifications are required in order to achieve the desired outcomes.

Reducing Biometric Risk and Controlling Disease

If the intent of a wellness program is to help improve the health of individuals so that future medical spending will be reduced, then it is critical to determine if the program is engaging the correct members and then measure the impact on their risk. At Vital Incite, we utilize Johns Hopkins’ risk indexing along with biometric risk migration to provide feedback to vendors and employers of the impact of their programs. Some suggested goals may include:

  • Engaging 80 percent of persons with high risk biometrics
  • Reduction in weight of persons overweight or obese by greater than 5 percent in 30 percent of the engaged population
  • Of diabetics with an A1c greater than 7 percent, 80 percent will reduce their A1c by 1 percent in one year
  • Of persons with blood pressure in the high-risk range, 40 percent will have achieved controlled blood pressure without adding medications in one year
  • Of persons who take fewer than 10,000 steps per day, 70 percent will increase their average step count by 20 percent or more

These goals need to be very specific and targeted to address the exact needs of your population, measuring what is most likely to have an impact on a person’s long-term health. This provides specific direction for your wellness providers, but allows an employer/consultant to monitor the impact throughout the year to continue to redirect communication and services to help provide the best outcomes.

The first step in any program is to engage the intended audience. UBA’s Health Plan Survey finds that 54.6 percent of employers with wellness programs use components such as on-site or telephone coaching for high-risk employees, an increase of 7.5 percent from last year. Once you target the intended audience, engagement of those at risk is critical. Monitoring this subset of data can make sure the vendor resources are directed appropriately and, many times, identify areas where the employer may be able to help.

Engagement of High Risk Individuals in CoachingOf course, engagement is only the first step and the intended outcome is to reduce risk or slow down the progression of risk increasing, that is really the final outcome desired. The following illustration allows employers and the vendor solution to monitor the true impact of the program by reviewing the risk control, or improvement based on program participation.

Participant vs non-participant results

Reducing Medical Spending

Although many employers are interested in helping their employees become healthier, the reality is these efforts have to help reduce medical costs or increase productivity so these efforts are sustainable. Since, to date, few employers have data on productivity, the analysis then is focused on reducing medical spending. The correct analysis depends on the size of your population and the targeted audience, but a general analysis to determine if those engaged are costing less than persons who have similar risk on your plan would look something like the analysis below.

participant engagement chart

If your program is targeted specifically on a disease state, then the impact on the cost to care for that disease state may be more appropriate. In the example below, the employer instituted a program to help asthmatics, and therefore, the analysis is related to the total cost to care for asthma comparing the year prior to the program to the year of the program. In this analysis, the impact is very clear.

Impact of Program on Cost for all ID-Asthma

The employer anticipated first year savings due to high emergency room (ER) utilization for persons with asthma and the report proved that along with ER utilization declining, the total cost of care for asthma significantly declined.

Summary

In summary, having a clear understanding of the expectation and desired outcomes and monitoring that impact throughout the year, we believe, drives better outcomes. When we first started analyzing outcomes of programs, the impact of many programs were far less impressive than vendor reports would allow us to believe. That false sense of security is not because they were trying to falsify information, but the reports did not provide enough detail to fully illustrate the impact. Most vendor partners don’t have access to all of the data to provide a full analysis and others will only show what makes them look good. But, if you identify the impact you need in order to achieve success, all parties involved focus on that priority and continually work to improve that impact. We believe that wellness programs can have an impact on a population culture, health and cost of care if appropriately managed.

Originally published by www.ubabenefits.com

Question: Are we required to allow employees (either exempt or nonexempt) to work from home if we must close the office due to bad weather?

Answer: No, employers are not required to allow employees to telework (work from home or another location; virtual work) under any specific weather conditions regardless of Fair Labor Standards Act (FLSA) exemption status. However, employers may allow employees to telework. Company policy should delineate procedures for both teleworking and notice requirements when inclement weather affects the workplace; for instance, notice from the employer that the workplace is closed and notice from the employee that they cannot travel to the workplace due to weather-related or other emergency conditions. These policies should be in the employee handbook, and should also detail whether the employer will allow nonexempt employees to make up missed time.

Note that if the employer closes the workplace for weather-related reasons, nonexempt employees are not entitled to pay because such employees are only entitled to compensation for hours actually worked. However, an employer may allow nonexempt employees to use accrued paid time off so as to receive compensation during such an absence. If paid time off is not available, then the time off remains unpaid.

Alternatively, exempt employees who are able and available to work but do not work because the employer closed the workplace due to inclement weather are still entitled to their full week of pay. This is because the exempt employee is available to work but rather the employer made the work unavailable. As a general rule, if an exempt employee performs any work during the workweek, they must be paid their full salary amount. An employer may not make deductions from an exempt employee’s pay for absences caused by the employer or by the operating requirements of the business. If the exempt employee is ready, willing and able to work, an employer cannot make deductions from the exempt employee’s pay when no work is available. Additionally, the U.S. Department of Labor specifically states that an example of an improper deduction from an exempt employee’s pay includes deduction of a days’ pay because the employer was closed due to inclement weather.

Originally published by www.thinkhr.com

Recently, the Department of the Treasury, Department of Labor (DOL), and Department of Health and Human Services (HHS) (collectively, the Departments) issued FAQs About Affordable Care Act Implementation Part 34 and Mental Health and Substance Use Disorder Parity Implementation.

The Departments’ FAQs cover two primary topics: tobacco cessation coverage and mental health / substance use disorder parity.

Tobacco Cessation Coverage

The Departments seek public comment by January 3, 2017, on tobacco cessation coverage. The Departments intend to clarify the items and services that must be provided without cost sharing to comply with the United States Preventive Services Task Force’s updated tobacco cessation interventions recommendation applicable to plan years or policy years beginning on or after September 22, 2016.

Mental Health / Substance Use Disorder Parity

Generally, the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) requires that the financial requirements and treatment limitations imposed on mental health and substance use disorder (MH/SUD) benefits cannot be more restrictive than the predominant financial requirements and treatment limitations that apply to substantially all medical and surgical benefits.

A financial requirement (such as a copayment or coinsurance) or quantitative treatment limitation (such as a day or visit limit) is considered to apply to substantially all medical/surgical benefits in a classification if it applies to at least two-thirds of all medical/surgical benefits in the classification.

If it does not apply to at least two-thirds of medical/surgical benefits, it cannot be applied to MH/SUD benefits in that classification.

If it does apply to at least two-thirds of medical/surgical benefits, the level (such as 80 percent or 70 percent coinsurance) of the quantitative limit that may be applied to MH/SUD benefits in a classification may not be more restrictive than the predominant level that applies to medical/surgical benefits (defined as the level that applies to more than one-half of medical/surgical benefits subject to the limitation in the classification).

In performing these calculations, the determination of the portion of medical/surgical benefits subject to the quantitative limit is based on the dollar amount of all plan payments for medical/surgical benefits in the classification expected to be paid under the plan for the plan year. The MHPAEA regulations provide that “any reasonable method” may be used to determine the dollar amount of all plan payments for the substantially all and predominant analyses.

MHPAEA’s provisions and its regulations expressly provide that a plan or issuer must disclose the criteria for medical necessity determinations with respect to MH/SUD benefits to any current or potential participant, beneficiary, or contracting provider upon request and the reason for any denial of reimbursement or payment for services with respect to MH/SUD benefits to the participant or beneficiary.

However, the Departments recognize that additional information regarding medical/surgical benefits is necessary to perform the required MHPAEA analyses. According to the FAQs, the Department have continued to receive questions regarding disclosures related to the processes, strategies, evidentiary standards, and other factors used to apply a nonquantitative treatment limitation (NQTL) with respect to medical/surgical benefits and MH/SUD benefits under a plan. Also, the Departments have received requests to explore ways to encourage uniformity among state reviews of issuers’ compliance with the NQTL standards, including the use of model forms to report NQTL information.

To address these issues, the Departments seek public comment by January 3, 2017, on potential model forms that could be used by participants and their representatives to request information on various NQTLs. The Departments also seek public comment on the disclosure process for MH/SUD benefits and on steps that could improve state market conduct examinations or federal oversight of compliance by plans and issuers, or both.

 

By Danielle Capilla, Originally published by United Benefit Advisors – Read More

Tis the season for company holiday parties. The time of year when employees gather to mix and mingle with co-workers outside of the normal work setting. It sounds like a merry ol’ time to most, but holiday parties can be a headache for HR leaders. While it’s a great opportunity to thank employees for all their hard work and let loose, it’s important to ensure it happens responsibly. Every year, ThinkHR publishes tips for making events safer to decrease potential hidden costs involved in employer-sponsored events (see Workday Holiday Parties–A Great Way to End the Year!)  This year we’ve broken it down into simple dos and don’ts to provide a high-level guide for executing this year’s festivities.

DO

Follow your stated employee policies. Keep in mind that holiday parties are employer-sponsored, so the company may be responsible for whatever happens at the party and sometimes for events that occur after the party. Be sure to emphasize that all guidelines will apply to the party even if it is off-site or after work hours.

Consider taking steps to limit alcohol consumption. If you decide that alcohol will be served and the party is off-site and after hours, provide plenty of food rich in carbs and protein to slow the absorption of alcohol into the bloodstream. You can also have a cash bar, limit the number of drink tickets or close the bar early to deter over-consumption.

Make sure your employees get home safely. Offer incentives to employees who volunteer to be designated drivers or arrange transportation and accommodations. Thinking ahead about transportation demonstrates responsibility on the employer’s part, as well as potentially minimizing the company’s liability if an employee causes an accident while driving under the influence.

Determine how to handle pay issues in advance of the party. It’s not required to pay employees that voluntarily attend a party after hours. However, nonexempt employees need to be compensated if they are working the party or if attendance is mandatory. If the party is held during regular work hours, then all employees would be paid for attending the party.

Make it a family affair. Experts suggest that employee behavior actually improves at company events when spouses or partners and children are present. If your budget allows, it can be a giant gesture to include the entire family in the celebration and one that many employees appreciate. Be sure to review your liability coverage with your broker first.

DON’T

Do not allow employees to get away with any bad behavior. Follow up on any complaints associated with the holiday party and conduct a thorough investigation. Racial or sexual jokes, gossiping about office relationships, and unwelcome touching should not be permitted during the holiday party just as they are not allowed in the office.

Do not make your party work related to avoid liability for any injuries. Typically, workers’ compensation does not apply if the injury is “incurred in the pursuit of an activity, the major purpose of which is social or recreational.” If the carrier determines that the company party was truly voluntary and not related to work, then the carrier would most likely deny the claim.

Do not penalize employees who choose not to attend. The message may be misinterpreted and could create employee relations concerns for those who may have other religious beliefs or are simply uncomfortable attending the event. Avoid religious symbols or themes as they could offend individuals of different faiths.

Do not serve alcohol if your policies do not permit drinking either on your company’s premises or during work hours and you plan to have the party at the office as a part of the workday. Remind your supervisors to set a good example, keep an eye out for employee behavior that needs managing, and to deter employees from any informal gathering after the party that gets the alcohol flowing.

Do not forget to reach out to your broker if you have any questions or concerns. The holidays are a great time to spread cheer, and holiday parties help sustain a positive work culture, but it’s important to be aware of potential issues that could arise and to plan accordingly. We’re here to help you along the way, as are your brokers, so be sure to leverage all of your resources.

Have more questions related to your company’s holiday party? Check out this Q&A from a recent ThinkHR webinar.

Originally published by www.thinkhr.com

Historically, employers have utilized health risk assessments (HRAs) as one measurement tool in wellness program design. The main goals of an HRA are to assess individual health status and risk and provide feedback to participants on how to manage risk. Employers have traditionally relied on this type of assessment to evaluate the overall health risk of their population in order to develop appropriate wellness strategies.

Recently, there has been a shift away from the use of HRAs. According to the 2016 UBA Health Plan Survey, there has been a 4 percent decline in the percentage of employer wellness programs using HRAs. In contrast, the percentage of wellness programs offering biometric screens or physical exams remains unchanged – 68 percent of plans where employers provide wellness offer a physical exam or biometric screening.

One explanation for this shift away from HRAs is an increased focus on helping employees improve or maintain their health status through outcome-based wellness programs, which often require quantifiable and objective data. The main issue with an HRA is that it relies on self-reported data, which may not give an accurate picture of individual or population health due to the fact that people tend to be more optimistic or biased when thinking about their own health risk. A biometric screening or physical exam, on the other hand, allows for the collection of real-time, objective data at both the individual and population level.

Including a biometric screening or physical exam as part of a comprehensive wellness program can be beneficial for both the employer and employees. Through a biometric screening or physical exam, key health indicators related to chronic disease can be measured and tracked over time, including blood pressure, cholesterol levels, blood sugar, hemoglobin, or body mass index (BMI). For employees, this type of data can provide real insight into current or potential health risks and provide motivation to engage in programs or resources available through the wellness program. Beyond that, aggregate data collected from these types of screenings can help employers make informed decisions about the type of wellness programs that will provide the greatest value to their company, both from a population health and financial perspective.

One success story of including a physical exam as part of a wellness program comes from one of our small manufacturing clients. From the initial population health report, the company learned that there was a large percentage of its population with little to no health data, resulting in the inability to assign a risk score to those individuals. It is important to note that when a population is not utilizing health care, it can result in late-stage diagnoses, resulting in greater costs and a burden for both the employee and employer. In addition, there was low physical compliance and a high percentage of adults with no primary care provider. In order to capture more information on its population and better understand the current health risks, the company shifted its wellness plan to include annual physicals as a method for collecting biometric data for the 2016 benefit year. Employees and spouses covered on the plan were required to complete an annual physical and submit biometric data in order to earn additional incentive dollars.

By including annual physicals in its wellness program, positive results were seen for employees and spouses and the company was able to make an informed decision about next steps for its wellness program. After the first physical collection period, the percentage of individuals with little to no information was reduced from 31 percent to 16 percent (Figure A). Annual physical compliance increased from 36 percent in 2015 to over 80 percent in 2016 (Figure B), which means more individuals were seeing a primary care provider. As a result of increased biometric data collection and one year of Vital Incite reporting, the company was able to determine next steps, which included addressing chronic condition management, specifically hypertension and diabetes, with health coaching or a disease management nurse.

Figure A – RUB Distribution 2014 – 2016

RUB Distribution 2014-2016

Figure B – Preventive Screening Compliance

Preventive Screening Compliance

Employers that are still interested in collecting additional information from employees may consider including alternatives to the HRA, such as culture or satisfaction surveys. These tools can allow employers the opportunity to evaluate program engagement and further understand the needs and wants of their employee population.

Originally published by www.ubabenefits.com

 

As an increasing number of Baby Boomers retire and leave the workforce, millennials are positioned to take on more leadership roles in the business world. Millennials bring with them a unique and evolving knowledge of technology and innovative HR practices that differ greatly from their Baby Boomer predecessors. As managerial roles are transferred from the Baby Boomer generation to millennials, forward-thinking businesses will create plans that adapt to the innovative processes and practices millennials bring to the table. Worthwhile risks and changes must be made to ensure companies keep up with their rapidly evolving competitors. To successfully transition millennials into top management positions, here are a few factors companies should keep in mind.

Millennials are technology-driven.

75% of millennials believe that technology helps them operate more efficiently in the workplace. Millennials are the first generation to truly incorporate technology as an imperative tool for maximum efficiency. Millennials look for efficiency, digital communication, and mobility founded in technology in the workplace, and use of technology helps facilitate innovation, engagement and clarity.  Baby Boomers in management who are getting ready to hand over the reins to their younger counterparts can facilitate a smooth operational transition by embracing new systems and processes led by technology.

Efficiency is key.

Millennials have grown up in a fast-paced culture where new technologies are constantly being developed, and because of this they find it natural to lean on technology to efficiently tackle daily work tasks. As opposed to previous generations, millennials are used to instant gratification and desire work to be completed in the most practical and timely manner. One example of state-of-the-art technology is automated task management systems which allow you to complete work ahead of time. For example, social media scheduling platforms like Hootsuite allow you to schedule posts ahead of time and select when you want them to post automatically. The automation process creates a more efficient way to complete time-consuming, yet simple tasks.  Another task management tool is Asana. Asana provides a single outlet for companies to manage projects, assign tasks and track progress, all through one system. Asana ensures a safe and organized portal for your company to complete tasks in the most practical manner.  Invest time in researching technological tools your millennial employees find helpful in their day-to-day work, and start implementing them now.

Digital communication is here to stay. 

Communication is vital to facilitating an engaged company culture. Being able to communicate well with not only clients, but with employees, is crucial. Millennials have grown up utilizing technology as a main form of communication, and they have mastered the art of making it work for them in the office as well. The mass amount of information that must be learned when implementing a new technology company-wide can be overwhelming, and keeping track of relevant news within your company can be difficult. To create an organized and effective internal communication strategy many companies are turning to social intranet software. This type of software creates a portal that keeps all of the company’s internal information in one place making mass communications easier to streamline. Digital communication fosters more efficient and timely transfer of information and problem solving. The impact of incorporating digital technology reaches beyond the office and can even help you prepare your employees to be social media advocates for your brand in their off time.

Mobility is the new norm. 

One of the most attractive assets of technology is mobility. Technology has completely disrupted the workplace by allowing employees to work anywhere at any time. Employees no longer have to complete their typical workday in the office. Working from home or remote locations provides room for great work/life balance and creative inspiration. A prime example of an effective technology when it comes to remote work and flexible hours is video conferencing through apps like Skype or FaceTime. By incorporating video conferencing, companies can easily expand their client base country wide and even internationally, at a much more cost effective price.

As millennials continue to take over the workforce and we see more innovations and improvements made to current technology, be sure your company stays up to date on the latest trends. Ensuring your employees are engaged with and fluent in technologies that are being globally implemented is vital to your company’s success in this digital age.

Millennials are currently the largest generation in the workforce, and statistics show they’re not going anywhere anytime soon. By 2020, millennials are projected to make up 50% of the workforce. As millennials continue to rise in numbers, companies are finding it harder to retain them in their current roles. A study conducted by Deloitte conveyed that 44% of millennials can see themselves switching jobs within two years of employment. Along with this, Gallup found that the millennial turnover rate costs the economy $30.5 billion every year.   These statistics clearly demonstrate that millennials’ expectations are not being met by current employers, so we’ve come up with a list of tips to help you design the perfect benefit plans and employee engagement strategies to attract top young talent.

More Benefit Choices

Contrary to traditional benefit plans where employers offer pre-crafted options, millennials want more say in what benefits they are offered. More choices including flexible work hours, work from home days and paid parental leave offer millennials the opportunity to achieve their ideal work-life balance which keeps them happy to work for your company long-term. Look at your benefit options as a company and assess how you can give your employees more freedom in their benefit choices.

Advancements

By nature, every employee wants to advance in their career. More specifically, millennials are extremely driven and tend to take jobs where they see an opportunity to be promoted quickly. Tower Watson conducted a study which found 41% of employees said they would leave their job if it meant they could advance their career. (http://blog.accessperks.com/employee-engagement-loyalty-statistics-the-ultimate-collection) Clearly, continuously promoting all of your employees is impractical. However, there are other ways to give your employees more power and opportunity to advance without promotions.

Many companies find success in giving millennials more responsibility and the opportunity to prove themselves in the workplace via co-managing projects with older, more experienced employees or trusting them more management oriented tasks. At the end of the day, millennials desire to have a substantial impact in their companies rather than just subscribing to the clock-in, clock-out mentality, and allowing them to have more responsibility furthers a sense of purpose in their work.

Positive Impact

Millennials are known for being a philanthropic generation, and they don’t want this mindset to change once they step into the office. Millennials are success-driven, but also desire to leave a positive impact on the world. Many companies participate in community outreach, so make that clear to both current and prospective employees. If you don’t currently sponsor community events or encourage your team to volunteer together, consider creating a simple initiative that allows your staff to give back and ask a millennial employee to spearhead it! Engage people through the spirit of service, and help the millennial generation see how they will impact society by joining your workforce.

The studies we’ve examined reveal that millennials have a like-minded outlook on what they value at work. They want more choices and flexible work options, opportunity for advancement, unique responsibility and to have a positive influence on not only their company, but on society as a whole. As more Baby Boomers retire and the workplace is faced with an influx of millennial workers, keep these perks in mind as you form your benefit plans and company culture!

timayerThis month we’re highlighting our Employee Benefits Advisor and Investment Advisor Representative, Tim Ayer! We’ve asked him a few fun questions to get to know him a little bit better!

What is your favorite aspect of your job?  The satisfaction created by helping people understand and navigate very complicated insurance and financial issues.

Do you have a favorite sports team?  Yes, I am a 40 year die-hard Cincinnati Bengals fan.  I guess that makes me somewhat of a glutton for punishment.

Do you have any collections or hobbies?  I love to fish and hunt when I get the chance.

Before working at Kaminsky & Associates what was the most unusual or interesting job you’ve ever had?  I worked as the VP General Manager of a concrete garden art company, which gave me the opportunity to travel to many parts of the United States that I otherwise wouldn’t have experienced.

What is an ability you wish you had?  Playing guitar.  I messed around with it for about a year but gave it up.

Did you know studies convey that 20% of the population, or 1 in every 5 adults suffer from some sort of mental health condition? Mental health has become a substantially concerning issue in America’s workplace, and therefore a top priority in employee wellness. Mental health conditions such as depression, anxiety, and bipolar disorder cause workers to perform less efficiently on a daily basis, which in turn creates negative effects on both the employees and employers.

Unaddressed mental health problems can leave employees unhappy and less efficient at work, as well as having financial consequences for employers. Studies conducted show that mental health conditions left without treatment cost employers nationwide a total of $80- $100 billion per year. In addition, employers have a duty to ensure physical and mental safety for their workers. In the past, companies have typically encouraged employees to see therapists and potentially receive medication. These treatments can be very effective. According to a recent study by the Partnership for Workplace Mental Health, 86% of those employees that were treated saw improvements in their daily work.

However, these therapy and medication can also be very time consuming and costly. In order to achieve a more efficient and cost effective solution, companies have found creative outlets to provide daily treatment. Enter the mental health app. Human Resources in general is becoming a more app-friendly department. The IAB-commissioned Harris Poll shows mobile phone users spend 88% of their time in applications and appreciate having apps that streamline services on their phones. There are countless apps for companies to choose from, but Mobylize and MoodNotes are two of the most innovative options.

Mobylize

Mobilyze is an employee-focused mobile application that tracks location, movement, sleeping patterns, and phone calls. It then compiles the data to analyze the user’s different moods and sends them messages as well as giving feedback on their responses to try and improve their symptoms. The app is user-specific which helps generate results faster and more accurately, and offers a more convenient and cost-effective option for companies trying to improve their employees’ well-being.

MoodNotes

Other apps, like MoodNotes, provide a more interactive user experience. Like Mobilyze, the app tracks different patterns that may be associated with mental health problems, but also focuses on creating a personal relationship with the user. MoodNotes encourages the user to answer more challenging questions about how they feel and why they may be feeling that way. As a result, the user is forced to think about possible suppressed problems and the reasons behind them. The app’s goal is to act like a mental health coach or friend, and strives to get users back to their healthy, happy selves.

These are only two examples of popular mental health apps that companies are starting to use. The companies that choose to implement these types of apps are continuing to see positive results. The market for mental health apps is growing, providing employees with many options to address specific issues and allowing room to find the best fit. As businesses focus on more ways to implement technology, mobile apps may be a solution to lowering the costs of mental health care, as well as looking out for the well-being of employees and fostering a well-functioning, healthy business environment.

 

By Nicole Federico

The U.S. Department of Health and Human Services’ (HHS) Office for Civil Rights (OCR) began a pilot program in 2012 to assess the procedures implemented by covered entities to ensure compliance with the Health Insurance Portability and Accountability Act (HIPAA). OCR evaluated the effectiveness of the pilot program and then announced Phase 2 of the program on March 21, 2016. Phase 2 Audits focus on the policies and procedures adopted by both covered entities and business associates to ensure they meet selected standards and implementation specifications of the Privacy, Security, and Breach Notification Rules. Covered entities include health plans, health care clearinghouses, and health care providers; whereas, business associates include anyone handling health information on behalf of a covered entity.

Phase 2 Audits of business associates focus on risk analysis, risk management, and reporting of HIPAA breaches to covered entities. OCR emphasizes the importance of audits as a compliance improvement activity in order to identify best practices and proactively uncover and address risks and vulnerabilities to protect health information (PHI).

OCR chose entities to audit through random sampling of the audit pool. Communications from OCR were sent via email, so it is important to check spam filters and junk emails for communications from OSOCRAudit@hhs.gov. OCR emailed a notice to verify contact information. Once the contact information was verified, OCR emailed a pre-audit questionnaire to gather data about size, type, and operations of the entity. This data was used with other information to develop pools of potential covered entities for making audit selections.

Phase 2 Audits consist of three sets of audits. The first set of audits will be desk audits of covered entities and the second set of audits will be desk audits of business associates. These audits will examine compliance with specific requirements of the Privacy, Security, or Breach Notification Rules and covered entities will be notified of their audit in a document request letter. All desk audits in this phase will be completed by the end of December 2016. OCR will select entities and request they electronically submit documentation within 10 days. The third set of audits will be onsite and examine a broader scope of requirements from HIPAA Rules.

On July 11, 2016, 167 covered entities were notified that they were selected for a desk audit. Desk audits of business associates will begin this fall. Download the complete Compliance Advisor, “HIPPA Phase 2 Audits” for best practices for covered entities facing desk or field audits.

Originally published by www.ubabenefits.com