1-3 I would love to be able to tell you that anyone who works with us will be 100% compliant - not going to happen. I do have clients that have no NPI available from time to time, however, human nature being what is it ... I can and usually do find customer files at will during my periodic assessments ... just far fewer of them. :-)

If you want to lower your risk ... you need to control who has access to customer information and know where it is at all times. You must have policies and procedures in place and processes to ensure compliance. Do you? If not or you don't know we can assist you.

                                                                                        The Compliance Guy