This second installment of my 2020 compliance discussion addresses the spectrum of 2020 Work Plan deliverables in addition to HIPAA compliance as contained in my previous article. Effective compliance programs recognize the need to follow developments across a broad-spectrum including litigation, legislation, and issues affecting privacy, security, and public health.

This compliance discussion addresses the discrete subject of ensuring 2020 Work Plans address Health Insurance Portability and Accountability Act (HIPAA) risk. HIPAA compliance cuts a broad swath of work. Your 2020 HIPAA Work Plan should—unsurprisingly--critically assess 2019 enforcement activity to focus scarce compliance resources in an optimal manner.

Following a US Supreme Court decision in the Azar v. Allina Health Services case in June 2019 (Azar v. Allina Health Services 139S.Ct. 1804 (2019)], the Department of Health and Human Services (HHS) undertook an analysis of the decision on Medicare payment rules and compliance actions based on those payment rules.In a 3-page memo dated October 31, 2019, general counsel for HHS made recommendations what should or should not be done in considering enforcement actions.

Following a US Supreme Court decision in the Azar v. Allina Health Services case in June 2019 (Azar v. Allina Health Services 139S.Ct. 1804 (2019)], the Department of Health and Human Services (HHS) undertook an analysis of the decision on Medicare payment rules and compliance actions based on those payment rules.In a 3-page memo dated October 31, 2019, general counsel for HHS made recommendations what should or should not be done in considering enforcement actions.

As the end of the year rapidly approaches, many people use lists to make sure they accomplish all their tasks.Below is a list a compliance officer may want to check one last time.