Specializing in Healthcare Compliance
Healthcare Compliance Is Not Optional—It’s Mission-Critical
For hospices, palliative care programs, skilled nursing facilities, and providers serving veterans, pediatrics, and individuals with disabilities, compliance is not a formality. It is the lifeline of your license, your funding, and your ability to operate.
Today’s post-acute care providers face unprecedented scrutiny from CMS, HHS, OCR, and private payers. If you bill Medicare, Medicaid, or commercial insurers, you are under direct oversight—with zero tolerance for lapses, delays, or documentation failures.
Failure is not theoretical—it’s real, accelerating, and unforgiving.
What’s Required—Now
To protect revenue and certification, providers must:
✅ Conduct and document Security Risk Analyses (SRA)
✅ Achieve and maintain HIPAA compliance
✅ Maintain audit-ready, defensible documentation
✅ Align operations with NIST, HIPAA, and Best Practices
Why HCCP Exists
Healthcare Compliance Certification Professionals (HCCP) is the nation’s only concierge compliance firm focused exclusively on hospice and post-acute care. We partner directly with executive leadership, compliance officers, and MSPs to:
✅ Safeguard Medicare/Medicaid reimbursements
✅ Prepare for CMS, HHS, and third-party audits
✅ Align policies and operations with HIPAA and best practices
✅ Conduct SRAs with enforceable corrective actions
✅ Protect your license, funding, and public trust
Noncompliance = Revenue Loss
This is not about checklists—it’s about survival. When compliance fails, the consequences are immediate and severe:
- Reimbursement suspensions
- Civil monetary penalties
- Involuntary Medicare/Medicaid termination
- Lawsuits, reputational damage, and operational shutdowns
Even a single outdated policy or incomplete SRA can trigger a full-scale audit and catastrophic funding loss.
HCCP = Structure. Oversight. Results.
At HCCP, we don’t offer templates. We build compliance systems that withstand real federal inspections.
We keep your organization:
✅ Structurally sound
✅ Audit-ready
✅ Revenue-secure
✅ Operationally resilient
HIPAA – Required
HIPAA: Two Core Rules Driving Compliance & Cybersecurity
1. HIPAA Privacy Rule:
Defines the permissible uses and disclosures of PHI, ensuring patient rights and confidentiality.
2. HIPAA Security Rule:
Requires Covered Entities and Business Associates to implement a comprehensive safeguard framework for electronic PHI (ePHI), including:
✅ Formal risk assessments
✅ Strong access controls and authentication
✅ Encryption of data in transit and at rest
✅ Defined incident response and breach protocols
✅ Ongoing workforce training
✅ Written breach notification procedures
Your Risk Is Real. Your Response Must Be Decisive.
Failure to meet even one of these obligations can result in:
- Audit findings
- Funding suspension
- Civil monetary penalties
- Public breach notifications
- Termination from Medicare/Medicaid participation
How HCCP Protects You
At Healthcare Compliance Certification Professionals (HCCP), we don’t just identify gaps—we close them. We operationalize compliance, train your workforce, prepare your documentation, and ensure your organization is both audit-ready and breach-resilient.
CMS Safeguards – Required
Compliance Isn’t Optional—It’s a Federal Mandate
If your hospice, palliative care program, or skilled nursing facility receives Medicare or Medicaid reimbursement, you are legally required to implement and maintain robust administrative, technical, and physical safeguards to protect both PHI and electronic PHI (ePHI).
These requirements are not advisory—they are binding conditions of participation under federal law.
CMS Mandates Strict Compliance With:
HIPAA Privacy, Security, and Breach Notification Rules
Regulate the use, disclosure, and safeguarding of patient health information.
The HITECH Act
Expands HIPAA by mandating breach notifications, increasing federal enforcement authority, and authorizing tiered civil monetary penalties for noncompliance—up to $1.9 million per violation category, per year.
42 CFR Part 2
Requires additional privacy protections for substance use disorder (SUD) treatment records—above and beyond HIPAA—impacting many palliative and hospice care settings.
Periodic Security Risk Analyses (SRAs)
Required under HIPAA, the HITECH Act, and CMS’s Promoting Interoperability Program. These assessments must be current, documented, and address evolving cyber threats and vulnerabilities.
CMS Reimbursement
What Medicare & Medicaid Require for Reimbursement
Healthcare providers that bill Medicare or Medicaid must comply with strict federal standards established by the Centers for Medicare & Medicaid Services (CMS), the U.S. Department of Health and Human Services (HHS), and the Office for Civil Rights (OCR). These are not recommendations—they are legal obligations tied directly to reimbursement eligibility.
What’s at Stake: Penalties, Enforcement & Funding Risk
Noncompliance is more than a paperwork issue—it is a regulatory violation with immediate financial and operational consequences. Providers that fail to meet federal requirements risk:
- Civil Monetary Penalties (CMPs) issued by HHS OCR
- Loss of Medicare and Medicaid eligibility
- CMS or state recoupment of previously paid claims
- Mandatory breach notifications and public reporting
- Damage to organizational reputation and trust
- Corrective Action Plans (CAPs) with heightened audit oversight
Core Compliance Requirements
✅ HIPAA Compliance (Mandatory)
HIPAA is a federal condition of participation in Medicare and Medicaid programs. To remain eligible, providers must:
- Safeguard Protected Health Information (PHI/ePHI)
- Implement administrative, physical, and technical controls
- Maintain privacy, security, and access control policies
- Conduct and document a current Security Risk Analysis (SRA)
✅ Security Risk Analysis (SRA) (Mandatory)
A properly documented SRA is a non-negotiable requirement under both the HIPAA Security Rule and CMS’s Promoting Interoperability Program. Every provider must:
- Identify and assess risks to patient health data
- Implement mitigation and remediation plans
- Show proof of annual review and continuous security improvement
Failure to maintain a current SRA can result in denied incentive payments, audit findings, sanctions, and loss of eligibility.
✅ HITECH Act Compliance (Mandatory)
The Health Information Technology for Economic and Clinical Health (HITECH) Act strengthens HIPAA by requiring:
- Breach reporting for unauthorized disclosures
- Audit logs and electronic accountability measures
- Encryption and integrity controls for EHR systems
HITECH directly links EHR adoption to compliance, ensuring transparency and accountability in healthcare IT systems.
Requirements & Strongly Recommended
Breach Notification Rule – Required
Under HIPAA and HITECH, any breach involving 500+ individuals must be reported to:
- HHS – within 60 days
- Affected individuals
- The media – when widespread impact is possible
Failure to comply triggers civil monetary penalties, reputational damage, and potential loss of Medicare/Medicaid participation.
NIST Cybersecurity Framework (NIST CSF) – Strongly Recommended
Referenced in HIPAA Security Rule guidance as an industry best practice. Providers use NIST CSF to:
- Identify and manage cybersecurity risks
- Improve infrastructure protection
- Prepare for audits and cyber events
CMS encourages alignment with:
- NIST SP 800-53 – Security & Privacy Controls
- NIST SP 800-66 Rev. 1 – Directly maps to HIPAA requirements
What’s Not Federally Required—But Increasingly Expected
In today’s healthcare environment, private payers, insurers, and strategic partners often demand stronger frameworks, even when not federally mandated:
- NIST 800-53 / 800-66 – Maps to HIPAA, often referenced in payer audits
- HITRUST CSF – Widely accepted; frequently required by payers and business associates
- SOC 2 / ISO 27001 – Not mandatory, but signals a mature security posture for organizations handling sensitive healthcare data
Mandatory Rules
CMS Program Integrity Rules – Mandatory
Providers must maintain programs to detect and prevent fraud, waste, and abuse (FWA) and ensure timely, accurate, and complete documentation. CMS requires:
- Breach reporting procedures
- FWA training for all staff
- Strong data security and access control practices
Noncompliance can trigger federal investigations, civil monetary penalties, exclusion from Medicare/Medicaid, and in severe cases, criminal liability.
Audit Readiness – Mandatory
Providers must be fully prepared for CMS and HHS audits, including:
- TPE (Targeted Probe & Educate)
- RAC (Recovery Audit Contractors)
- UPIC/ZPIC (Unified Program Integrity Contractors / Zone Program Integrity Contractors)
- HIPAA & OCR audits
Readiness requires maintaining:
- Current compliance documentation
- Security Risk Analyses (SRAs)
- Workforce training records
- Incident response and breach management plans
- Executed Business Associate Agreements (BAAs)
State Medicaid Requirements – Mandatory (Varies by State)
Medicaid providers must comply with state-specific security and health IT requirements, which may include:
- Enhanced encryption and cybersecurity policies
- State-mandated data-sharing agreements
- Additional compliance or reporting programs
OCR & CMS Audits – Required Compliance
Both random and complaint-driven audits evaluate whether providers can demonstrate:
- Security Risk Analysis documentation
- Policies and procedures aligned to HIPAA and CMS requirements
- Current Business Associate Agreements
- Workforce training logs
- Breach response plans and documented incident reports
Eligible & Compliant
To remain eligible for Medicare and Medicaid reimbursement—and to stay operational—healthcare providers must meet key compliance and security requirements established by HHS, CMS, and OCR. Failure to comply risks audit failures, financial penalties, and potential loss of program participation.
Core Requirements for Eligibility & Compliance
✅ Annual SRAs – Identify vulnerabilities and document remediation
✅ Policies & Procedures – Maintain HIPAA Privacy, Security, and Breach policies
✅ Workforce Training – Train staff yearly on HIPAA, cybersecurity, and incident response
✅ Documentation – Keep accurate, defensible care, billing, and compliance records
✅ Access Controls & Audit Logs – Monitor all PHI access with role-based controls
✅ Billing & Coding – Ensure accurate CPT/ICD coding supported by justifiable services
✅ Internal Audits – Conduct regular self-audits to detect and correct gaps
✅ Audit Readiness – Keep records organized for unannounced or investigative audits
✅ BAAs – Secure valid agreements with all PHI-handling vendors
✅ Encryption & Backups – Encrypt PHI and routinely test backup restoration
✅ Regulatory Monitoring – Stay current with HHS, CMS, and OCR updates
✅ Incident Response Plan – Maintain a documented breach response protocol
Special Note
Recent audits by the U.S. Department of Health and Human Services (HHS) revealed that more than 80% of covered entities and business associates failed to conduct a proper Security Risk Analysis (SRA)—a core requirement under the HIPAA Security Rule.
While exact data on Medicare audit failures tied solely to incomplete SRAs is limited, the high failure rate demonstrates a systemic compliance gap that directly influences audit outcomes.
Failure to perform or adequately document an SRA can result in severe consequences, including:
- Civil monetary penalties
- Reimbursement penalties under Meaningful Use and MIPS programs
- Loss of Medicare and Medicaid funding eligibility
Bottom line: Comprehensive, up-to-date SRAs are not optional—they are the foundation of HIPAA compliance and a critical safeguard for protecting your organization’s revenue.
Is Your Hospice Ready for a Federal Audit?
Compliance Mandate
Why Compliance Isn’t Optional
If your hospice provides care under Medicare, compliance is not optional—it is a federal mandate. Providers are now under heightened scrutiny by CMS, the Office of Inspector General (OIG), and the Office for Civil Rights (OCR).
Certification failures, audit findings, and billing errors are no longer minor issues. They are triggering:
- Heavy civil monetary penalties
- Recoupment of past reimbursements
- Exclusion from Medicare participation
HCCP exists to protect providers from this exact outcome. We ensure your organization is audit-ready, defensible, and funding-secure—so you can focus on delivering compassionate care without fear of regulatory disruption.
Regulatory Reality
What’s Happening Now
- 40% of hospices failed to comply with Medicare billing or care delivery standards.
Source: HHS OIG Compliance Review Summaries, 2023 - $190 million in improper payments were made by Medicare between 2017–2021 due to invalid outpatient billing during the hospice perioHospice Modernization Initiative, May 2023
- $162 million recovered by CMS Recovery Audit Contractors in a single year.
- Civil penalties of $500 to $10,000 per instance can be issued by CMS for noncompliance with Conditions of Participation.ds.
Source: OIG Audit A-01-21-00500, March 2024 - 7,000+ unannounced hospice site visits were conducted by CMS in 2023. Nearly 400 providers were flagged for enforcement action.
Source: CMS Press Release,
Compliance Risk
Compliance failures are not minor setbacks—they are existential threats to your funding and operations. Providers risk:
- Termination from the Medicare program
- Recoupment of previously paid claims (overpayments)
- Civil monetary penalties
- Loss of licensure or certification
- Severe damage to reputation and referral relationships
Common Causes of Failure
- No current, documented Security Risk Assessment (SRA)
- Incomplete or outdated HIPAA policies and procedures
- Missing workforce training documentation
- Inconsistent compliance records, billing errors, or audit gaps
How HCCP Protects You
We help hospice, palliative care, and skilled nursing providers achieve and maintain full Medicare compliance through:
- HIPAA & CMS CoP Alignment – Ensuring policies, procedures, and safeguards meet federal conditions of participation.
- Audit Readiness Strategies – Preparing documentation, staff, and systems for unannounced or investigative reviews.
- Certification Documentation Development – Building defensible records for surveys, audits, and recertification.
- Cybersecurity & Risk Assessments – Conducting SRAs and implementing corrective actions tied to HIPAA and NIST.
- Remediation & Policy Enforcement – Closing compliance gaps and enforcing accountability across the organization.
We don’t sell software.
We deliver outcomes:
✅ Certification maintained
✅ Audits defended
✅ Operations protected
Our Service Packages
We provide four levels of support, ranging from baseline assessments to executive-level certification defense.
Gold Tier – Assessment Package
Foundational review of your HIPAA posture, Security Risk Analysis (SRA), and CMS compliance risks. Includes baseline reporting and a certification roadmap.
Platinum Tier – Remediation Package
Corrective actions, policy updates, advanced SRAs, Conditions of Participation (CoP) alignment, and staff readiness training. Delivers audit-defensible documentation.
Diamond Tier – Executive Readiness Package
Comprehensive certification strategy, penetration testing, executive tabletop exercises, and real-time risk dashboards. Designed for multi-location or high-risk providers.
Senior Advisor Package
Embedded strategic oversight, with direct support through audit events, monthly compliance reviews, and board-level briefings.
Next Steps
We offer a complimentary readiness consultation to determine where your organization stands—and how to close critical gaps before CMS or OCR finds them.
[ Schedule Your Strategy Call ]
HCCP is your national partner in hospice, palliative care, and skilled nursing compliance—delivering certification defense, audit readiness, and operational protection.
© 2025 Healthcare Compliance Certification Professionals
Healthcare Compliance Certification Professionals (HCCP) provides national, non-clinical compliance and certification support services exclusively to hospice providers, including HIPAA compliance, Security Risk Assessments (SRA), Medicare documentation, staff training, and audit preparedness. Based in Maryland, HCCP does not provide medical care and operates independently from the Centers for Medicare & Medicaid Services (CMS), the U.S. Department of Health and Human Services (HHS), and all other regulatory agencies. Our mission is to help hospice organizations meet and maintain Medicare compliance standards with confidence, clarity, and accountability.
