Does Your Compliance Program Meet OMIG Standards? Key Changes for Your Healthcare Organization to Implement in 2019
If your organization is licensed under Article 28 or 36 of the New York State Public Health Law, or Article 31 or 16 of the New York State Mental Hygiene Law and bills, claims, or receives money from the Medicaid program or Managed Medicaid payers, or you are any organization or person that does, or expects to, submit at least $500,000 in Medicaid claims over a 12-month consecutive period, the NYS Office of the Medicaid Inspector General (OMIG) requires you to implement a compliance program aimed at detecting and reducing the potential for fraud, waste, and abuse. All providers under these licensures must certify annually that a sufficient compliance program is in place.
This year, OMIG has issued several updates which may affect these providers. OMIG has (1) expanded the certification categories, (2) requires the Provider ID and National Provider Identifier Number (NPI) to be included in the certification form, and (3) no longer requires providers to separately affirm satisfaction with each of the eight required elements of a compliance program – all elements are now consolidated into a general certification statement affirming that a compliance program is in place that meets all requirements under NYS law.
While providers no longer need to individually affirm each of the eight requirements, compliance programs still must meet each of the elements defined under SSL § 363-d and Part 521. All providers subject to the requirements should conduct an annual self-assessment to ensure that all eight elements are satisfied prior to certification. Now is the time to conduct this self-assessment and determine if any gaps exist in your policies and procedures.
Contact CohnReznick if you would like to discuss how these changes might affect you, or if you need assistance completing your self-assessment to ensure your compliance program satisfies the required OMIG elements.