Employers are all too familiar with the more common investigation efforts by government agencies, such as an EEOC investigation blossoming from a single employee Title VII or ADEA charge into an onsite investigation of purported pattern and practice violations, or HHS turning a self-reported breach into a broad review of HIPAA compliance. But the government is increasingly expanding and using its investigation tools in less common areas. Audits are in the air – are you ready?
Consider whether your policies, practices and files are in order on the following subjects:
- Health Plan Audits under the Health Benefits Security Project (“HBSP”): This audit initiative is part of the Employee Benefits Security Administration (“EBSA”) National Enforcement Projects. It includes a broad range of healthcare investigations as well as enforcement of the Affordable Care Act (“ACA”). More specifically, EBSA will review plans for documentary and operational compliance