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ITT Technical Institutes Closed – What You Should Know
Nov 8th, 2016 by aperio

ITT Technical Institutes Closed As of September 6, 2016

ITT Educational Services, Inc., announced that it will be discontinuing academic operations at all of its ITT Technical Institutes permanently. They state that they have eliminated the positions of more than 8,000 employees, and refer to “tens of thousands of unexpectedly displaced students [who will need help] with their records and future educational options.”

Specifically in the Sacramento area, this means that the ITT Technical Institute in Rancho Cordova has been shuttered, “…leaving more than 400 students without an immediate option to finish their education.” (Allen Young, Sacramento Business Journal.) The Sacramento area has experienced additional school closures in the recent past, including Heald College in Roseville and Rancho Cordova and three University of Phoenix campuses.

Did ITT Fail to Deliver on Its Educational Promise to Students?

In its press release, ITT claimed that “…federal actions will result in the closure of ITT Technical Institutes without any opportunity to pursue our right to due process.” The press release states that ITT “…exhausted the exploration of alternatives, including transfer of the schools to a non-profit or public institution.” ITT also states that they were not provided with a hearing or an appeal.

However, other sources describe a different situation. Gizmodo’s Technology Editor, Michael Nunez, stated in his article on ITTs closure that “ITT Tech and other for-profit colleges have been widely criticized for accepting billions of dollars in government loans while failing to provide adequate job training for its students.”

Sanctions Before Closure Spelled the End

Only days before the closure, ITT had been barred from accepting new students who were using federal loans to finance their educations. These sanctions were driven by concerns about ITT’s business and recruiting practices: “ITT Tech… had been facing accusations from its accreditor of chronic financial mismanagement and questionable recruiting tactics. It is also under investigation by more than a dozen state and federal authorities, including the Massachusetts attorney general, the Consumer Financial Protection Bureau and the Securities and Exchange Commission.” (Melissa Korn, Wall Street Journal)

The Future for ITT Students, Including 35,000 Veterans

The future for now-former ITT students is unclear. Although ITT has been legally required to maintain cash reserves to help support students in case of company closure, Gizmodo reports that the company “is not saying how it will use its reserves,” with ITT maintaining that their press release will be their only comment.

Where Can Students Get More Information?

The Department of Education issued a letter from the Secretary of Education to ITT students on September 6, 2016, providing guidance and links to their ITT announcements page. Initially, students face two basic options: discharge of student loans (under some circumstances); or attempting to transfer credits to other institutions.

However, Leada Gore notes on the Alabama website that students may face unexpected difficulties. For example, if a student is in default of student loans at the time of the closure, they may be ineligible for discharge of their loan.

Even more worryingly, “Veterans attending ITT will be covered under the same provisions related to loan discharge. However, veterans cannot be credited for the months of eligibility under G.I. Bill already used while at ITT. As many as 35,000 veterans attend ITT, according to Student Veterans of America.

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HIPAA Compliance – Phase 2 Audit FAQs and the Audit Protocol
Nov 8th, 2016 by aperio

Figuring out the details of whether your business is in compliance with HIPAA is an ongoing challenge. At our last HIPAA related Lunch & Learn event, several of our attendees were looking for information on how HIPAA will be conducting its latest phase of audits – how businesses will be selected to be audited (particularly business associates), when the different types of audits will be conducted, and more. Here are some of the latest answers from the Health and Human Services Office for Civil Rights

 

HIPAA Compliance – FAQs and the Audit Protocol

The OCRs website offers some helpful definitions and answers to frequently asked questions concerning the audit process. A few important highlights include:

 

  • Timing for audits – The Health and Human Services Office for Civil Rights (OCR) began audits for Phase 2 of the HIPAA Audit Program back in March 21, 2016. The OCR states that “Phase 2 is currently underway. Selected covered entities [CE] received notification letters July 11, 2016. Business associate [BA] audits will start in the fall.” The OCR also warns businesses to double check that the emails are not blocked by any spam filters.

 

  • Basis for selecting those who will be audited – The OCR states that for Phase 2, they are “identifying pools of CEs and BAs that represent a wide range of health care providers, health plans, health care clearinghouses, and business associates.” Their plan is to examine a broad spectrum of candidates to allow them to better understand the state of HIPAA compliance across the industry.

 

As far as BAs go, the OCR will be asking CEs who are being audited “to identify their business associates.” They encourage CEs “to prepare a list of each business associate with contact information so that they are able to respond to this request.”

 

  • Different sets of audits – The OCR’s first set of audits will be desk audits of CEs, followed by a second set of desk audits of BAs. The third set of audits will be onsite, with some desk auditees being subjected to onsite audits. (You can take a look at the OCR 2016 HIPAA Desk Audit Guidance on Selected Protocol Elements for additional details.)

 

You can also take a look at the actual audit protocol along with some definitions of terms at the OCR’s website. This lengthy table breaks down the audit protocol according to Audit Type, Section, Key Activity, Established Performance Criteria, and the Audit Inquiry.

What do you know about HIPAA?
Nov 2nd, 2016 by aperio


HIPAA is constantly changing an updating its regulations.? There are still tons of companies that are currently operating without even knowing they need to be HIPAA compliant.? It’s hard to stay on top of the all the changes so if you ever have any questions then please feel free to contact us about any questions you may have regarding HIPAA certification.? You may already be required and could face paying some hefty finds.? You have questions so call us at 916.568.6830 or contact us via form:

CONTACT US!

 

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